In Davies, Collector v. Corbin & Others, the Supreme Court of the United States was asked to decide whether the federal government had the authority to impose a tax on the sale of distilled spirits. The case arose when the Collector of Internal Revenue attempted to collect a tax from the defendants, who had purchased distilled spirits from a distiller in Kentucky. The defendants argued that the tax was unconstitutional because it was not authorized by Congress. The Supreme Court held that the federal government had the authority to impose the tax. The Court reasoned that the power to tax was an inherent power of the federal government, and that Congress had the authority to impose taxes on the sale of distilled spirits. The Court also held that the tax was not a violation of the Constitution because it was not a direct tax, and therefore did not require apportionment among the states. The Court's decision in Davies, Collector v. Corbin & Others established that the federal government had the authority to impose taxes on the sale of distilled spirits. The decision also established that the tax was not a direct tax, and therefore did not require apportionment among the states.

In Davies, Collector v. Corbin & Others, the Supreme Court was asked to decide whether a tax imposed by Congress on distilled spirits manufactured in the United States and exported from it was constitutional. The majority opinion held that such a tax did not violate any provision of the Constitution and thus could be lawfully collected. However, Justice Field dissented from this decision arguing that Congress had no power to impose taxes upon exports as doing so would interfere with foreign commerce which is solely within the purview of states under their police powers granted by Article I Section 10 Clause 3 of the Constitution. He further argued that since there were already existing state laws governing taxation related to exports, allowing for federal taxation would create an unnecessary conflict between state and federal law which should be avoided if possible.