The Forged Steel Wheel Company v. Lewellyn case in 1919 revolved around a dispute over tax assessment and collection. The Forged Steel Wheel Company, a Pennsylvania corporation, was assessed for additional taxes by the Commissioner of Internal Revenue under the War Revenue Act of 1917. The company paid these taxes but later filed a claim for refund with the collector of internal revenue, arguing that they were incorrectly assessed as their profits did not exceed pre-war levels - an exemption provided in Section 301(a) of the act. When their claim was rejected, they sued to recover this amount plus interest from Mr. Lewellyn who was then Collector of Internal Revenue for Pennsylvania's twenty-third district. The Supreme Court ruled against Forged Steel Wheel Co., stating that while there may have been errors made during calculation or interpretation by lower courts or officials regarding what constituted "pre-war profit", it did not change the fact that any business whose income exceeded reasonable returns on capital and investments should be taxed accordingly under wartime legislation.

The dissenting opinion in the case of Forged Steel Wheel Company v. Lewellyn, Collector of Internal Revenue for the Twenty-Third District of Pennsylvania argued that the tax imposed on corporations by Congress was not a direct tax but an excise tax. The justice disagreed with the majority's interpretation that this was a direct tax and therefore unconstitutional without apportionment among states according to population. He asserted that it is within Congress' power to levy taxes on income from any source derived, including corporate profits, as long as they are uniform throughout all states. Furthermore, he contended that there is no constitutional requirement for such taxes to be apportioned based on census data or state populations. In his view, upholding this law would not infringe upon any individual rights nor violate principles of federalism because it does not disproportionately burden certain states over others.