•“ The Revenue Act of 1916, in so far as it imposes a tax upon the stockholder because of such dividend, contravenes the provisions of article 1, 2, cl. 3, and article 1, 9, cl. 4, of the Constitution, and to this extent is invalid,notwithstanding the Sixteenth
Amendment.” Eisner v. Macomber, 252 U.S. 189,219