In the 1923 case of Manufacturers' Land & Improvement Company v. United States Shipping Board Emergency Fleet Corporation and Public Service Railway Company, the Supreme Court ruled in favor of the defendants. The plaintiff, a land development company, had leased property to the U.S. Shipping Board during World War I for shipbuilding purposes but claimed that it was not adequately compensated for damages incurred by its tenant's sublessee (Public Service Railway). The court held that under federal law governing wartime leases, any claim against a government corporation must be brought within six months after war termination or from when cause of action accrued; hence this suit was time-barred as it was filed more than two years after WWI ended. Furthermore, they found no evidence supporting claims that defendant corporations conspired to defraud plaintiff out of proper compensation.

In the dissenting opinion for Manufacturers' Land & Improvement Company v. United States Shipping Board Emergency Fleet Corporation and Public Service Railway Company, it was argued that the majority's decision to uphold a lower court ruling in favor of the U.S. Shipping Board Emergency Fleet Corporation (EF) was incorrect. The dissenting justices believed that EF should not be exempt from paying taxes on property it leased from Manufacturers' Land & Improvement Co., as this exemption would unfairly burden other taxpayers who are required to pay their fair share of taxes. They also disagreed with the majority's interpretation of federal law, arguing that Congress did not intend for government corporations like EF to have such broad tax exemptions. Furthermore, they contended that allowing these types of exemptions could potentially lead to abuse by enabling private entities to avoid taxation through arrangements with government corporations.