This case was a dispute between the taxpayers, Goldenberg and another, and the Collector of Internal Revenue, Murphy. The taxpayers argued that the Collector had wrongfully assessed them for taxes on the profits of a certain business transaction. The Collector argued that the transaction was taxable under the Internal Revenue Act of 1864. The Supreme Court held that the Collector was correct in his assessment. The Court found that the transaction was taxable under the Internal Revenue Act of 1864, and that the Collector had the authority to assess the taxes. The Court also held that the Collector was not required to provide the taxpayers with a hearing before assessing the taxes. The Court concluded that the Collector had acted within his authority in assessing the taxes, and that the taxpayers were liable for the taxes. The Court also held that the Collector was not required to provide the taxpayers with a hearing before assessing the taxes.

In Goldenberg and Another v. Murphy, Collector (1883), the Supreme Court was asked to decide whether a tax imposed on foreign-made cigars imported into the United States violated the Constitution's prohibition against direct taxes not apportioned among states according to their population. The majority of justices held that it did not violate this provision because it was an indirect tax, rather than a direct one. Justice Field dissented from this opinion, arguing that while Congress had authority under its power to regulate commerce with foreign nations and among several states to impose duties or imposts upon imports, such powers could only be exercised in accordance with constitutional limitations; namely, that all direct taxes must be apportioned according to state populations as specified by Article I Section 9 of the Constitution. He argued further that since there were no facts presented which showed how much each state would have been required to pay if such a duty had been assessed in proportionate amounts based on population figures for each state - as is required by law - then any attempt at taxation without proper apportionment constituted an unconstitutional exercise of power by Congress.