In the 1927 case of Atwater & Company v. United States, the U.S Supreme Court ruled on a matter concerning federal income tax law. The petitioner, Atwater & Company, was an investment firm that had purchased and sold securities for its own account as well as for customers' accounts. The company claimed deductions from gross income based on losses incurred in these transactions but did not include gains made during the same period in their taxable income calculation. This practice led to a dispute with the Internal Revenue Service (IRS). Upon review by lower courts, it was determined that such deductions were not permissible under existing tax laws at that time. The Supreme Court upheld this decision upon appeal by Atwater & Co., ruling against them unanimously. They agreed with lower court rulings stating that any losses incurred from sales of securities could only be deducted if corresponding gains were also included in gross income calculations - essentially asserting fair balance within taxation practices where both profits and losses are considered together rather than separately or selectively.

The dissenting opinion in the case of ATWATER & COMPANY v. UNITED STATES argued that the majority's decision to uphold Atwater & Company's conviction for selling misbranded food products was incorrect. The dissenters believed that there was insufficient evidence to prove beyond a reasonable doubt that Atwater had intentionally deceived consumers about the quality and nature of its product, which they considered a necessary element for conviction under the Pure Food and Drug Act. They also expressed concern over potential misuse of this law by government officials who might use it as an excuse to harass businesses without just cause or due process protections. Therefore, they would have reversed the lower court’s ruling convicting Atwater & Company.