This case was a dispute between the administratrix of the estate of a deceased man, and the United States. The administratrix, Brown, was seeking to recover money that had been paid to the United States by her deceased husband. The money had been paid as a tax on the sale of certain property. The United States argued that the tax was valid and should not be refunded. The Supreme Court held that the tax was not valid, and that the United States was liable to refund the money to the administratrix. The Court reasoned that the tax was not authorized by the statute under which it was imposed, and that the United States had no right to collect it. The Court also held that the United States was not entitled to any interest on the money, as the tax was not valid. In conclusion, the Supreme Court held that the United States was liable to refund the money to the administratrix, and that it was not entitled to any interest on the money. The Court's decision was based on the fact that the tax was not authorized by the statute under which it was imposed.

In Brown, Administratrix v. United States, the Supreme Court was asked to determine whether a widow of an officer in the Navy was entitled to receive pay for her husband's services after his death. The majority opinion held that she was not eligible for such compensation because there were no statutory provisions allowing it at the time of her husband's service and death. Justice Field dissented from this decision on two grounds: firstly, he argued that Congress had intended to provide widows with benefits when they passed legislation granting pensions and other forms of relief; secondly, he contended that even if Congress did not intend to grant these benefits at the time of passage, equity demanded them due to their long-standing practice in similar cases involving military personnel who died while serving their country. In conclusion, Justice Field believed that denying Mrs. Brown’s claim would be unjust and contrary both legislative intent as well as equitable principles established by prior decisions regarding veterans' rights upon death or disability incurred during service