Page "Pollock v. Farmers' Loan & Trust Co." Paragraph 2

The provisions of the Wilson-Gorman Tariff Act of 1894 required that, for a five-year period, any " gains, profits and incomes " in excess of $ 4, 000 would be taxed at 2 %.

So, in compliance with the Act, the New York-based Farmers ' Loan & Trust Company announced to its shareholders that it would not only pay the tax, but also provide to the collector of internal revenue in the Department of the Treasury the names of all people for whom the company was acting and thus were liable for being taxed under the Act.