The Taxing Power: A Reference Guide to the U.S. Constitution
Much or this book will focus on the history and the meaning of the explicit limitations on the taxing power – the Uniformity Clause, the Direct-Tax Clauses, and the Export Clause-and the history and meaning of the Sixteenth Amendment. The book will also examine son1e other, once important restrictions on the national taxing power that were derived from the constitutional structure or from specific constitutional provisions that are silent about taxation. For example, at one time, congressional power to tax almost anything associated with states or municipalities has understood to be forbidden by the doctrine of intergovernmental immunity. The impact of that doctrine has been substantially diminished by judicial developments, but it may retain a modicum of importance.
Jensen, Erik M., "The Taxing Power: A Reference Guide to the U.S. Constitution" (2005). Faculty Publications. 1330.