Article XLIV (44) is the part of the Massachusetts constitution that deals with taxation of the Commonwealth’s residents. It created taxation on “income”, but required that it “be levied at a uniform rate”. The article was adopted in 1915. It was not until the Supreme Judicial Court’s ruling in Raymer v. Tax Commissioner (1921) that the amendment was interpreted as a flat tax for all sources of income. Originally the amendment was thought to only apply to “income derived from different classes of property” but in 1921 the definition of property was expanded to include labor and service in Raymer.