In the 1892 case Hollender v. Magone, the United States Supreme Court ruled on a dispute involving customs duties. The plaintiff, Hollender, imported goods from France and claimed that he was overcharged by the defendant, Magone who was a collector of customs in New York. The main issue revolved around whether or not certain discounts given to Hollender by French manufacturers should have been included in calculating the dutiable value of his imports under U.S law at that time which stated that duty had to be paid on "the actual market value or wholesale price" of such merchandise in its country of origin. The court held for Magone stating that these rebates were essentially retroactive reductions in purchase price and therefore should have been factored into determining dutiable value. This decision clarified how import values were calculated for purposes of assessing custom duties.

In the dissenting opinion for Hollender v. Magone, Justice Brewer argued that the majority's interpretation of tariff laws was incorrect. He believed that Congress intended to tax imported merchandise based on its condition at the time of arrival in the United States, not when it left its country of origin. Therefore, he disagreed with imposing a duty on sugar based on its quality before being damaged during transport. He also pointed out inconsistencies in previous court decisions regarding similar cases and suggested that these discrepancies indicated a misunderstanding or misapplication of congressional intent concerning tariff laws. Ultimately, Justice Brewer asserted that duties should be assessed according to an item’s value upon reaching American shores rather than their initial worth prior to potential damage incurred during transit.