In the case of Chicago Distilling Company v. Stone in 1890, the U.S. Supreme Court ruled on a dispute involving tax laws related to distilled spirits. The Chicago Distilling Company had been assessed for taxes by Collector Stone based on an estimate of their production capacity rather than actual output, which they argued was unfair and illegal under existing tax law at that time. However, the court upheld this method of taxation as valid under federal law and within the discretion granted to collectors by Congress. The ruling clarified that distilleries could be taxed based on their potential production if it was deemed more accurate or convenient than measuring actual output, even if this resulted in higher taxes for some businesses.

In the dissenting opinion for the case of Chicago Distilling Company v. Stone, it was argued that the tax imposed on distilled spirits should be considered as a duty or impost rather than an excise tax. The justice held that according to Article I, Section 8 of the Constitution, Congress has power to lay and collect taxes but not duties or imposts without regard to uniformity throughout all states. He believed that this provision was intended by framers to prevent favoritism among different parts of country in levying such charges. Therefore, he disagreed with majority's interpretation which allowed federal government to impose non-uniform taxes on goods produced within states under guise of excise taxation. Furthermore, he contended that if this ruling were upheld it would give Congress unlimited power over state industries and destroy balance between federal and state governments established by Constitution.