In the case of Felsenheld v. United States (1901), the U.S Supreme Court ruled on a matter concerning customs duties. The plaintiff, Mr. Felsenheld, imported iron bands into the country and was charged with a duty under paragraph 193 of the Tariff Act of July 24, 1897 as "bands or hoops." He protested this classification and claimed that they should have been classified under paragraph 184 as "iron in slabs," which would result in lower duties. The court held that while these items could be considered both 'bands' and 'slabs,' it is necessary to consider their commercial designation at time of importation rather than just their physical characteristics when determining appropriate tariff classifications. As such, since they were commercially known as bands at time of importation, they were correctly classified by customs officials for purposes of imposing tariffs.

The dissenting opinion in Felsenheld v. United States argued that the majority's decision was inconsistent with previous court rulings and interpretations of the law. The dissent contended that a tax on legacies or distributive shares arising from personal property should not be considered as direct taxes, but rather indirect ones, which do not need to be apportioned among states according to their population. They believed this interpretation was more consistent with the Constitution's intent and historical precedent. Furthermore, they disagreed with the majority’s view that such a tax could have an oppressive effect on certain states or individuals due to its potential for unequal application across different types of property and wealth levels.