The U.S. Supreme Court case Dane v. Jackson, Treasurer and Receiver-General in 1920 revolved around the issue of taxation on federal securities held by a Massachusetts trust company for non-residents of the state. The plaintiff, Dane, argued that such taxation was unconstitutional as it violated Article I Section 10 Clause 2 (the Import-Export Clause) and Article IV Section 2 (the Privileges and Immunities Clause) of the Constitution. However, the court ruled against him stating that these clauses did not apply to this situation because they were intended to prevent discrimination between residents and non-residents rather than regulate tax laws within states themselves. Furthermore, it was decided that since Massachusetts law allowed for taxes on all property located within its borders regardless of ownership location or status; therefore there was no violation present in this case.

The dissenting opinion in the case of Dane v. Jackson, Treasurer and Receiver-General argued that the majority's decision was an overreach of judicial power. The dissenters believed that it was not within the court's jurisdiction to determine whether or not a tax is constitutional based on its purpose or effect, as this would infringe upon legislative powers. They contended that if a tax is levied for public purposes and does not violate any express constitutional limitations, then it should be deemed lawful regardless of its economic impact or underlying motives. In their view, courts should refrain from interfering with fiscal policies unless they clearly contravene specific constitutional provisions.