In the case of Aluminum Castings Company v. Routzahn, the U.S. Supreme Court was tasked with determining whether a taxpayer could claim a refund for overpayment of taxes due to an error in calculating depreciation on property used in its business operations. The Aluminum Castings Company had initially claimed and received refunds for 1918 and 1919 but later discovered that it had made errors in computing depreciation allowances which resulted in additional tax liability for those years. When they sought to recover these amounts from the government, their claims were denied by lower courts on grounds that they were barred by statute of limitations. The Supreme Court reversed this decision, ruling that when taxpayers have paid more than what is legally due because of mistakes or errors not attributable to negligence or fraud, they are entitled to recover such excess payments if claims are filed within four years after payment was made regardless of any statutory limitation period provided under law at time payment was made.

In the dissenting opinion for Aluminum Castings Company v. Routzahn, Justice Stone argued that the majority's decision was inconsistent with previous rulings and principles of tax law. He contended that a taxpayer should not be allowed to claim a refund on taxes paid under protest when they had already taken advantage of an available statutory remedy by filing a claim for abatement before payment. According to him, allowing such double recovery would undermine the purpose of these remedies and create unnecessary confusion in tax administration. Furthermore, he disagreed with the majority's interpretation of "overpayment" in Section 3226 Revised Statutes as including payments made under protest after denial of an abatement claim; instead, he believed it only referred to instances where too much money was collected due to mathematical or factual errors rather than legal disputes over liability.