The Court further stated in rejecting the claim that the income tax is laid as a direct tax:

•“…it clearly results that the proposition and the contentions  under it, if acceded to, would cause one provision of the Constitution to destroy another; that is, they would result in bringing the provisions of the Amendment exempting a direct tax from apportionment into irreconcilable conflict with the general requirement that all direct taxes be apportioned.”
[Brushaber v. Union Pac. R.R., 240 U.S. 1, 12]