the tax is constitutional and Congress has this power under the taxing power granted to it in the Constitution. The tax did produce some revenue, and the Court will not analyze Congressional motives for imposing it. Further, the tax was within the national taxing power. Congress, the Court reasoned, could determine the subjects of taxation, and could choose some while omitting others. The Court also explained that the tax in question was not a penalty imposed for the purpose of enforcing regulations, which would be beyond the scope of the taxing power.
Congress has the power to impose taxes reasonably related to its taxing power. More importantly, if Congress acts pursuant to a power granted to it by the Constitution, the Court will not analyze the motives behind the regulation.