In the 1943 case Dobson v. Commissioner of Internal Revenue, the United States Supreme Court ruled on a matter concerning tax law and its interpretation by lower courts. The issue at hand was whether or not losses incurred from selling securities could be deducted from gross income for tax purposes under Section 117(d) of the Revenue Act of 1938. The Board of Tax Appeals had previously allowed such deductions, but this decision was reversed by Circuit Courts in several cases including Dobson's. In a unanimous ruling, the Supreme Court held that only Congress has authority to change interpretations made by administrative agencies like the Board of Tax Appeals regarding ambiguous provisions in tax laws unless there is clear evidence that these interpretations are incorrect or unreasonable. Therefore, it reinstated previous decisions allowing taxpayers to deduct losses from sales of securities against their gross income.

In the dissenting opinion for Dobson v. Commissioner of Internal Revenue, Justice Robert H. Jackson argued that the majority's decision to uphold the Board of Tax Appeals' ruling was incorrect and inconsistent with previous court decisions. He contended that it was not within the purview of a federal appellate court to review factual determinations made by administrative bodies such as tax courts unless there is clear evidence of fraud or gross error in judgment. In this case, he believed there were no grounds for overturning the board's findings because they were based on substantial evidence and reasonable interpretations of existing tax laws. Furthermore, he criticized his colleagues for overstepping their judicial authority by substituting their own views on complex economic matters for those of experienced administrators who are better equipped to handle them.