In the case of Board of County Commissioners of the City and County of Denver v. Home Savings Bank, 1914, the U.S Supreme Court ruled on a dispute involving tax assessments. The Home Savings Bank had purchased property at a tax sale after its previous owners failed to pay taxes on it. Later, when additional unpaid taxes were discovered from before the bank's purchase, Denver attempted to collect these back-taxes from Home Savings Bank. The bank argued that they should not be held responsible for these past-due amounts as they were not disclosed during their acquisition process. The court sided with Home Savings Bank stating that while municipalities have broad powers in assessing and collecting taxes; those powers must be exercised fairly and justly without violating due process rights under Fourteenth Amendment protections. Therefore, since there was no notice given about existing liens or arrears during the time of purchase by Home Saving Banks; it would violate their due process rights if forced to pay them retrospectively.

The dissenting opinion in the case of Board of County Commissioners of the City and County of Denver v. Home Savings Bank argued that the majority's decision to uphold a tax assessment on property owned by a non-resident was incorrect. The dissenters believed that this ruling violated principles of equal protection under law, as it unfairly targeted non-residents for taxation while exempting residents from similar taxes. They also disagreed with the majority's interpretation of Colorado state law regarding tax assessments, arguing that it did not provide sufficient grounds for taxing non-residents at higher rates than residents. Furthermore, they contended that such differential treatment could discourage investment and economic growth within Colorado by deterring out-of-state individuals or entities from purchasing property in the state due to fear of excessive taxation.