In the case of American National Company, Receiver v. United States (1926), the Supreme Court dealt with a dispute over tax liability. The American National Company was appointed as receiver for an insolvent corporation and sold its assets to pay off creditors. However, it did not set aside funds to cover federal taxes that had been assessed against the corporation before insolvency but were unpaid at the time of receivership appointment. The government argued that under section 280(a) of the Revenue Act of 1924, such taxes should be paid out from any proceeds derived from selling corporate property in receivership before other claims are settled. The Supreme Court ruled in favor of the U.S., stating that when a company is placed into receivership due to bankruptcy or insolvency, any outstanding federal tax liabilities take precedence over other debts during asset liquidation process by virtue of their nature as excise taxes imposed on corporations' privilege to do business under protection provided by Federal laws and regulations.

In the dissenting opinion for the case of American National Company, Receiver v. United States (1926), Justice Oliver Wendell Holmes Jr., disagreed with the majority's interpretation of tax law. He argued that a corporation should not be taxed on income derived from property it had sold and subsequently leased back because this transaction did not result in any actual gain or profit to the company. Instead, he viewed these transactions as merely changing the form of an investment rather than creating new wealth subject to taxation. According to him, taxing such transactions would amount to double taxation since both initial sale and subsequent lease payments were being taxed separately even though they essentially represented same economic activity - use of property by lessee corporation.