The U.S. Supreme Court case Cortelyou v. Charles Eneu Johnson & Company in 1907 revolved around the interpretation of tariff laws and their application to imported goods, specifically sugar. The defendant, Charles Eneu Johnson & Company, argued that they should be refunded for duties paid on raw sugar imports because the Secretary of Treasury had incorrectly interpreted a provision in the Dingley Tariff Act (1897). This act imposed different tariffs depending on whether sugars were above or below No.16 Dutch standard color grade; however, there was disagreement over how this grading system applied to polariscope tests used to determine sugar quality and purity levels. The court ruled against Charles Eneu Johnson & Co., stating that it is within the authority of administrative officials like the Secretary of Treasury to interpret ambiguous provisions in tariff acts as long as their interpretations are reasonable and not plainly inconsistent with law.

In the dissenting opinion for the case of Cortelyou v. Charles Eneu Johnson & Company, Justice Harlan disagreed with the majority's interpretation of a provision in an act that imposed taxes on corporations' net income. He argued that this tax was not intended to be a direct tax but rather an excise or duty. According to him, it was levied against businesses engaged in interstate commerce and did not violate any constitutional provisions regarding taxation without representation as claimed by the plaintiff corporation. Furthermore, he contended that if such taxes were deemed unconstitutional because they were directly imposed on property owners without apportionment among states according to population, then many other forms of federal taxation would also have to be declared invalid under similar reasoning. This could potentially disrupt government operations funded through these means and undermine Congress's power granted by Constitution over national finances.