The case of Massachusetts et al. v. United States in 1947 revolved around the issue of federal taxation and its applicability to state-owned liquor stores operating under local alcoholic control laws. The states argued that their operations were immune from federal taxes due to the principle of intergovernmental tax immunity, which prevents one level of government from taxing another. However, the Supreme Court ruled against this argument by a vote of 6-3, stating that these state-run businesses did not enjoy such immunity as they were engaging in commercial activities rather than traditional governmental functions. This ruling established an important precedent for determining when state entities could be subject to federal taxation.

The dissenting opinion in the case of Massachusetts et al. v. United States argued that the federal government did not have the right to tax state-owned liquor stores, as it infringed upon states' rights and violated principles of federalism. The justices contended that allowing such taxation would give Congress undue power over state functions and could potentially lead to a dangerous concentration of power at the national level. They believed this was contrary to the intent of America's founding fathers who sought a balance between state and federal powers through their design of U.S constitution. Furthermore, they expressed concerns about potential interference with states' abilities to carry out essential public services if subjected to excessive or discriminatory taxes by Congress.