Luther was strongly opposed to the sale of “indulgences”. Members of the Catholic Church were expected to pay the church for penance that covered certain types of sins. The pressure on the part of the believers to subscribe to such payments was the belief that unconfessed sins increased the time for one’s stay in purgatory.
Luther became increasingly angry about the clergy selling 'indulgences' - promised remission from punishments for sin, either for someone still living or for one who had died and was believed to be in purgatory. On 31 October 1517, he published his '95 Theses', attacking papal abuses and the sale of indulgences
In McCulloch v. Maryland (1819) the Supreme Court ruled that Congress had implied powers under the Necessary and Proper Clause of Article I, Section 8 of the Constitution to create the Second Bank of the United States and that the state of Maryland lacked the power to tax the Bank.
