Comment: The case of Pollock did not

The case of Pollock did not eliminiate the income tax on wages. It eliminated the income tax on income derived from interest, rent, and dividends. That was what the specific part of the Wilson-Gorman act that the court found was unconstitutional.

"First. We adhere to the opinion already announced—that, taxes on real estate being indisputably direct taxes, taxes on the rents or income of real estate are equally direct taxes.
Second. We are of opinion that taxes on personal property, or on the income of personal property, are likewise direct taxes.
Third. The tax imposed by sections 27 to 37, inclusive, of the act of 1894, so far as it falls on the income of real estate, and of personal property, being a direct tax, within the meaning of the constitution, and therefore unconstitutional and void, because not apportioned according to representation, all those sections, constituting one entire scheme of taxation, are necessarily invalid.
The decrees hereinbefore entered in this court will be vacated. The decrees below will be reversed, and the cases remanded, with instructions to grant the relief prayed. [158 U.S. 601, 638] "

Also, as aforementioned, 42 states ratified the 16th amendment.