In the case of Ford Motor Co. v. United States in 2013, the U.S Supreme Court ruled against Ford Motor Company's claim for a refund on overpaid taxes due to interest expenses related to a debt restructuring that occurred in the late 1980s and early 1990s. The court held that these interest expenses were not deductible under Section 163(a) of the Internal Revenue Code because they did not meet certain requirements for deductibility, including being paid or accrued within the taxable year and carrying a true obligation of repayment. Therefore, Ford was denied its request for an $875 million tax refund from federal authorities.

The dissenting opinion in the case of Ford Motor Co. v. United States disagreed with the majority's interpretation of a statute related to customs duties, arguing that it was overly narrow and contrary to legislative intent. The dissent argued that Congress intended for companies like Ford to be able to seek refunds on overpaid customs duties when they could demonstrate that they had been charged more than what was legally required under their contracts. They contended that the majority's decision effectively denied these companies any meaningful opportunity for judicial review, which is inconsistent with fundamental principles of administrative law and due process rights. Furthermore, they believed this ruling would have negative implications for U.S businesses by making them less competitive internationally as it increases costs associated with importing goods into the country.