The Court in Springer held that the federal income tax imposed on the income of Mr Springer which happened to consist of his income from his profession of the practice of law and interest income on US bonds as the Court later noted in Pollock was not a direct tax and was not required to be apportioned Nowhere in the Springer case did the Court rule that excises or duties were limited to nonlicensed andor noncorporate activities contrary to what the language you provided seemed at least to me to imply  Pollock in NO WAY overturned the last remaining vestiges of the Springer case In the two Pollock cases the Court held ONLY that an income tax on interest income dividend income and rent income was to be treated as a direct tax a tax on the income from property was treated as a tax on the property itself and was required to be apportioned This was only a partial overruling of Springer The Pollock Court did NOT hold that the income tax in general was a direct tax The Pollock holdings were limited ONLY to taxes on income from property meaning interest income dividend income and rent income  The only part of Springer overruled in Pollock was the portion of the Springer holding dealing with the income tax on interest income from bonds  More to come later