The U.S. Supreme Court case Flint v. Stone Tracy Company in 1910 revolved around the constitutionality of a federal tax law that imposed taxes on corporations based on their income, which was part of the Corporation Tax Act of 1909. The plaintiffs argued that this act violated the Constitution's uniformity clause and due process clause, as well as its prohibition against direct taxation without apportionment among states according to population. However, the Supreme Court upheld the law's constitutionality with an unanimous decision (9-0). The court ruled that corporate income could be taxed differently from individual income because corporations enjoyed certain benefits and protections not available to individuals under state laws such as limited liability for shareholders and perpetual life; thus it did not violate any constitutional provisions regarding taxation.

In the dissenting opinion for Flint v. Stone Tracy Company, Justice Harlan argued that the tax imposed by Congress on corporations based on their income was unconstitutional. He contended that it was a direct tax not apportioned according to state populations as required by Article I of the Constitution. Furthermore, he disagreed with the majority's interpretation of what constitutes an excise tax, stating that such taxes are traditionally levied upon use or consumption and not simply because an entity exists in a certain form (i.e., as a corporation). Therefore, he believed this corporate income tax violated constitutional principles regarding taxation and federalism.