This case was a dispute between the United States and two individuals, Edye and another, over the collection of taxes. Edye and the other individual had purchased certain bonds from the United States, and the United States had imposed a tax on the bonds. Edye and the other individual argued that the tax was unconstitutional, as it was not authorized by any law. The Supreme Court held that the tax was valid, as it was authorized by the Constitution. The Court reasoned that the Constitution gave Congress the power to impose taxes, and that the tax in question was a valid exercise of that power. The Court also held that the tax was not a violation of the due process clause of the Constitution, as it was not an arbitrary or oppressive tax. The Court thus affirmed the decision of the lower court, which had upheld the tax.

The dissenting opinion in Edye and Another v. Robertson, Collector argued that the Court should not have overturned a decision by the Circuit Court of Appeals for the District of Columbia which held that an income tax imposed on citizens was unconstitutional. The dissenters felt that since Congress had no power to impose such taxes under Article I, Section 8 of the Constitution, it could not delegate this authority to any other branch or department of government. Furthermore, they argued that if Congress did possess such power then it would be necessary for them to pass laws specifically authorizing taxation before any action could be taken against taxpayers who failed to pay their taxes. They concluded by stating that while there may be some ambiguity as regards how much authority is granted under Article I, Section 8 with respect to taxation matters; however this does not give Congress unlimited powers when it comes to levying taxes on its citizens without due process and proper authorization from law-making bodies.