The Massachusetts Trustees of Eastern Gas & Fuel Associates v. United States case in 1963 revolved around the issue of whether a corporation could claim depreciation deductions on property owned by its subsidiary but used by the parent company. The Supreme Court ruled that such deductions were not permissible under federal tax law, as it was deemed that only the legal owner of a property - in this case, the subsidiary - had rights to any associated tax benefits. This decision upheld an earlier ruling made by a lower court and reinforced existing interpretations regarding ownership and taxation within corporate structures.

In the dissenting opinion for Massachusetts Trustees of Eastern Gas & Fuel Associates v. United States, Justice Harlan disagreed with the majority's interpretation of Section 5(2)(a) of the Interstate Commerce Act. He argued that this section should not be interpreted to allow a railroad company to abandon its operations without first obtaining approval from the Interstate Commerce Commission (ICC). According to Justice Harlan, such an interpretation would undermine Congress' intent in enacting this provision - which was primarily aimed at preventing railroads from unilaterally discontinuing services that are essential for public convenience and necessity. Furthermore, he contended that if a railroad could simply cease operations by transferring all its assets and liabilities to another entity without ICC approval, it would render meaningless other provisions in the Act requiring ICC authorization before any significant changes can be made in rail service or facilities. Therefore, he concluded that such transfers must also require prior ICC consent under Section 5(2)(a), contrary to what was decided by the majority.