In the case of Manning, Collector of Internal Revenue v. Seeley Tube & Box Co., the U.S Supreme Court ruled in favor of Seeley Tube & Box Company. The company had paid an excess profits tax during World War II under protest and sued for a refund, arguing that it was entitled to relief under Section 722 of the Internal Revenue Code which provided tax benefits for businesses whose profits were inflated due to war conditions. The IRS denied their claim on grounds that they did not meet all requirements stipulated by this section. However, upon reaching the Supreme Court, it was determined that while Seeley didn't meet every requirement explicitly stated in Section 722(b)(4), they met its spirit as their business experienced abnormality in income due to war circumstances beyond their control; hence should be granted relief from excessive taxation.

In the dissenting opinion for Manning v. Seeley Tube & Box Co., Justice Jackson disagreed with the majority's interpretation of Section 122(b)(2) of the Internal Revenue Code. He argued that this section should not be interpreted to allow a business to carry back its net operating loss from one year and offset it against profits made in previous years, thereby reducing tax liability retrospectively. Instead, he believed that such an interpretation was inconsistent with both legislative intent and sound tax policy. According to him, allowing businesses to adjust their taxes retroactively would create uncertainty in revenue collection and could potentially lead companies into financial difficulties if they had already spent or invested money paid as taxes on earlier profits.