The Supreme Court case Territory of Alaska et al. v. Troy, Collector of Customs for the District of Alaska in 1921 revolved around a dispute over taxation powers between the federal government and the territory of Alaska. The issue at hand was whether or not certain goods imported into Alaska from other parts of the United States were subject to customs duties under an act passed by Congress in 1909, which imposed such duties on all merchandise coming into any "insular possession" (i.e., territories) from outside that territory's borders. The court ruled against the Territory of Alaska, stating that as a non-incorporated U.S. territory it did not have full constitutional protections and thus could be subjected to these import taxes despite being part of America geographically.

In the dissenting opinion for the case Territory of Alaska et al. v. Troy, Collector of Customs for the District of Alaska, Justice McReynolds argued that Congress did not intend to grant full territorial status to Alaska when it passed an act in 1912 providing a civil government for the territory. He maintained that this act was merely intended as a temporary measure until such time as Congress could establish a more permanent form of government. Therefore, he contended that customs duties collected on goods shipped from other parts of United States into Alaska should be considered imports and thus subject to taxation under federal law rather than being exempted as domestic shipments within U.S territories would be.