In the case of Levy et al. v. Wardell, United States Collector of Internal Revenue for the First District of California, et al., 1921, the Supreme Court was tasked with determining whether a tax assessment on an estate could be made after the statutory period had expired due to an extension granted by mutual agreement between parties involved. The court ruled in favor of Wardell and held that such extensions were permissible under law as long as they were agreed upon before expiration of original time limit set by statute for making assessments. This decision clarified that while statutes do impose certain limits on government action, these can be modified through mutual consent if done within legal parameters.

In the dissenting opinion for Levy et al. v. Wardell, United States Collector of Internal Revenue for the First District of California, Justice Holmes disagreed with the majority's decision to uphold a tax on foreign-built yachts owned by American citizens and used in domestic waters. He argued that this was not an import duty but rather a discriminatory tax against property based solely on its place of manufacture, which he believed violated principles of equal protection under law. Furthermore, he contended that such taxation could potentially lead to retaliatory measures from other countries and disrupt international trade relations - something Congress likely did not intend when it passed the tariff act in question.