In Allis v. United States (1894), the U.S. Supreme Court ruled on a dispute involving customs duties imposed on imported machinery parts intended for repair purposes. The Edward P. Allis Company, an American industrial equipment manufacturer, argued that these parts should be exempt from import taxes as they were not finished products but components used to restore existing machinery to its original condition. However, the court upheld the decision of lower courts and sided with the government's argument that these items were dutiable under customs laws because they could be considered "manufactured articles". The ruling clarified that even if such goods are meant for repairing or rebuilding purposes, it does not change their character as manufactured articles subject to duty fees upon entering U.S territory.

In the dissenting opinion for Allis v. United States, Justice Brewer argued that the majority's interpretation of the law was incorrect and overly broad. He contended that Congress did not intend to tax all income derived from property but only income in its ordinary sense - profits made through business or trade. According to him, a broader interpretation would lead to absurd results such as taxing unrealized gains on property appreciation which he believed was clearly not intended by lawmakers. Furthermore, he disagreed with the majority's view that interest paid on bonds should be taxed as it is essentially a return of capital rather than profit or gain. In his view, this decision could potentially discourage investment and harm economic growth because investors might be less willing to lend money if they knew their returns would be subject to taxation.