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Well, the short answer is that the Constitution does not define what income is. Congress via the IRS does. Now, I am interested to see if Article I, Section 9, Clause 4 "No Capitation, or other direct, Tax shall be laid, unless in proportion to the Census or Enumeration herein before directed to be taken" gets litigated in relation to Obamacare in 2014-2015.
It would not be interpreted as a direct tax but one of choice. One can choose to purchase insurance, if required, or pay a tax in lieu of doing so...