In Pacific Insurance Company v. Soule (1868) 74 U.S. 433, the taxes in question were upon the receipts of such companies from premiums and assessments, and upon all sums made or added, during the year, to their surplus or contingent funds. This court held unanimously that the taxes were not direct taxes, and that they were valid. In Pacific Insurance Co. v. Soule, referring to the unlimited nature of the power of taxation conferred upon Congress, it was observed p. 443: "Congress may prescribe the basis, fix the rates, and require payment as it may deem proper. Within the limits of the Constitution it is supreme in its action. No power of supervision or control is lodged in either of the other departments of the government."