In the case of Del Vecchio et al. v. Bowers, 1935, the U.S Supreme Court ruled in favor of Bowers who was a collector for the Internal Revenue Service (IRS). The plaintiffs, Del Vecchio and others were stockholders in an Italian bank that had been liquidated by Mussolini's government. They claimed they did not owe income tax on their share of profits from this liquidation because it was involuntary and therefore should be considered as capital gains rather than ordinary income under US law at that time which taxed them differently. However, the court held that even though these shareholders didn't voluntarily choose to liquidate their shares, they still received a financial gain from it which is taxable as income regardless of its source or nature.

In the dissenting opinion for Del Vecchio et al. v. Bowers, Justice Stone argued that the majority's decision to uphold a state law requiring foreign corporations to consent to being sued in local courts as a condition of doing business within the state was unconstitutional. He contended that this requirement violated due process rights by forcing companies into an unfair choice between surrendering their right to be sued only in their home jurisdiction or forfeiting their ability to conduct business within another state entirely. Furthermore, he believed it infringed upon interstate commerce protections by allowing states too much power over out-of-state businesses and potentially discouraging economic activity across borders. In his view, such laws could lead towards protectionism and disrupt national unity if each state were allowed unchecked authority over foreign corporations operating within its boundaries.