DIRECT OR INDIRECT, NEVER BOTH
•Income tax, like any tax, can ONLY be either a direct tax, or an indirect tax, it CANNOT BE BOTH. 
•That is why there is no liability for income tax established anywhere in the Subtitle A statutes except for Section 1461, which
•Indirectly establishes the liability of the Withholding Agents for the tax that they have withheld from the subject foreign taxpayers.