Jasper L. Cummings, Jr. (Alston & Bird, Durham, NC), 222 Years of the Supreme Court, the Constitution, and Federal Tax, 133 Tax Notes 1151 (Nov. 28, 2011):

Cummings argues that the Supreme Court has played a more useful role in creating income tax law than is generally supposed. The Court has also fostered a very expansive view of the federal power to tax, which will be tested by the pending healthcare tax case, not because the legal attacks are well founded but because, as in the days of Pollock, there is a confluence of impassioned advocacy and a receptive Court.

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