In Hixon v. Oakes, the U.S Supreme Court dealt with a dispute over land ownership in North Dakota. The plaintiff, Hixon, claimed that he had purchased the land from its original owner and therefore held rightful title to it. However, the defendant, Oakes argued that he was entitled to the property because of his long-term possession and use of it under "adverse possession" laws - a legal principle which can allow someone who has openly occupied and used another's property for an extended period without challenge to claim ownership rights. The court ruled in favor of Hixon stating that adverse possession requires continuous occupation for at least 20 years before one can claim ownership rights over a piece of land they do not hold title to; since Oakes' occupation did not meet this requirement, he could not assert such claims against Hixon's legally recognized purchase.

In the dissenting opinion for Hixon v. Oakes, it was argued that the majority's decision to uphold a tax on intangible property contradicted previous rulings and principles of fairness. The dissent emphasized that this type of taxation could lead to double taxation, as both tangible assets (like land or buildings) and intangible ones (like stocks or bonds) could be taxed separately even though they are intrinsically linked. This would result in an unfair burden on taxpayers who own such properties. Furthermore, the dissent pointed out inconsistencies with past court decisions which had ruled against similar forms of double taxation. It was also noted that there were practical difficulties in assessing the value of intangible property for tax purposes, making it potentially arbitrary and unjust.