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Furthermore, the Supreme Court has explicitly confirmed, in Insurance Co. v. New Orleans, 13 F. Cas. 67 (C.C.D. La. 1870), Orient Ins. Co. v. Daggs, 172 U.S. 557, 561 (1869), and Paul v. Virginia, 75 U.S. (8 Wall.) 168 (1869) that Citizens of the United States within the meaning of this Amendment must be natural and not artificial persons; a corporate body is not a citizen of the United States. Since the Fourteenth Amendment definition of "citizen" and these decisions all precede the Revenue Act, the Act must therefore NOT be referring to a "legal person" and must instead be referring to a natural person.
Furthermore, the text of the Revenue Act does include certain terms which make its definition of person as natural person abundantly clear. On page 168 we have:
>That there shall be deducted from the amount of the net income of each of said persons, ascertained as provided herein, the sum of $3,000, plus $1,000 additional if the person making the return be a married man with a wife living with him, or plus the sum of $1,000 additional if the person making the return be a married woman with a husband living with her.The net income of each of said persons, ascertained as provided herein, which I quoted earlier, refers to "every citizen of the United States, whether residing at home or abroad, and to every person residing in the United States, though not a citizen thereof." And it specifies here that each of said taxable persons who would be taxed may be either a MAN or a WOMAN. This explicitly disproves the theory that persons in the context of the Revenue Act refers to artificial or legal persons.
