In the case of Arthur C. Harvey Co. v. Malley et al., Former Collector, 1932, the U.S Supreme Court was tasked with determining whether a tax assessment on imported merchandise was valid under federal law and regulations at that time. The plaintiff, Arthur C. Harvey Company had imported goods from foreign countries which were assessed for taxes by customs officials upon their arrival in the United States based on an increased value due to advances in foreign exchange rates between the date of exportation and date of importation into America. The company challenged this assessment arguing it should be based solely on the market value at place and time of export rather than any subsequent increase due to fluctuating exchange rates during transit period. However, after careful consideration, including review of relevant statutes as well as Treasury Department's interpretation thereof; The Supreme Court ruled against Arthur C.Harvey Co., upholding validity of such assessments made by customs officials. They concluded that while there may have been some ambiguity regarding how these laws should be applied; given longstanding practice and consistent administrative interpretation supporting this method - it would not be appropriate for them to overturn such established precedent without clear evidence showing Congress intended otherwise.

In the dissenting opinion for Arthur C. Harvey Co. v. Malley et al., Justice Stone argued that the majority's decision was inconsistent with previous rulings of the court and undermined established principles of tax law. He contended that a taxpayer should not be penalized for failing to pay an additional tax when they had no reason to believe such a tax was due, especially given that it was imposed retroactively by Congress after their return had been filed and accepted by government officials without objection or demand for further payment. Furthermore, he maintained that if there were any doubts about whether taxpayers could reasonably have anticipated this new liability, these should be resolved in favor of taxpayers rather than against them as per traditional legal norms.