“ In the one the clause of the Constitution was considered which forbids any state, without the consent of Congress, to 'lay any imposts or duties on imports or exports,' and in the other, that 'no tax or duty shall be laid on articles exported from any state.' The distinction between direct and indirect taxes was not involved in either case.
The sale of stocks is a particular business transaction in the exercise of the privilege afforded by the laws in respect to corporations of disposing of property in the form of certificates. ”

“ The stamp duty is contingent on the happening of the event of sale, and the element of absolute and unavoidable demand is lacking. As such it falls, as stamp taxes ordinarily do, within the second class of the forms of taxation. ”

“ The present case involves a stamp tax on a memorandum or contract of sale of a certificate of stock, which plaintiff in error claims was unlawfully exacted because not falling within the class of duties, imposts, and excises, and being, on the contrary, a direct tax on property.
There is no occasion to attempt to confine the words duties, imposts, and excises to the limits of precise definition. ”