In the case of Heinze v. Arthur's Executors, 1891, the U.S Supreme Court was tasked with determining whether a contract for the sale of goods could be enforced if it had not been fully executed at the time one party died. The dispute arose from an agreement between Mr. Heinze and President Chester A. Arthur before his death in which Heinze agreed to purchase several tons of iron from Arthur’s estate but failed to pay after receiving only part of it due to Arthur's demise. The court ruled that even though full delivery hadn't occurred prior to Arthur's death, this did not invalidate their contract or excuse non-payment by Heinze because contracts are binding upon heirs and executors unless explicitly stated otherwise within them or they involve personal services that cannot be performed by others. This decision established legal precedent regarding contractual obligations following a party’s death; specifically, that such obligations generally survive beyond someone’s life unless there is clear evidence suggesting otherwise.

In the dissenting opinion for Heinze v. Arthur's Executors, Justice Lamar disagreed with the majority's interpretation of tax law and its application to this case. He argued that a tax on income derived from property should be considered a direct tax, which according to the Constitution must be apportioned among states based on population. The majority held that such an income tax was not a direct but rather an excise or duty, thus exempt from apportionment requirements. However, Justice Lamar contended that this view distorted constitutional principles and could lead to unfair taxation practices in future cases. He maintained that any revenue generated by property—whether through rent or sale—should be treated as part of the property itself for taxation purposes; therefore subjecting it to apportionment rules under direct taxes.