The U.S. Supreme Court case Miller, Collector of Internal Revenue v. Standard Nut Margarine Company of Florida in 1931 revolved around the issue of taxation on colored oleomargarine. The Standard Nut Margarine Co., a manufacturer and dealer of nut margarine, challenged the tax imposed by Congress on its product under the Oleomargarine Act of 1886 which levied higher taxes for colored oleomargarine than uncolored ones as it was considered a substitute for butter. The company argued that this act violated their rights to equal protection under law as per the Fourteenth Amendment because there was no substantial difference between colored and uncolored margarines apart from appearance. However, the court ruled against them stating that Congress had valid reasons to impose different tax rates based on coloration due to potential consumer deception where consumers could mistake cheaper margarine for more expensive butter if they were similar in color.

In the dissenting opinion for Miller v. Standard Nut Margarine Co., Justice Stone argued that the tax imposed on colored oleomargarine was not a regulatory measure but rather a revenue-raising one, and thus should be considered valid under Congress's broad taxation powers. He contended that it is not within the Court's jurisdiction to question or limit Congress’s motives in imposing taxes, as long as they do not infringe upon constitutional rights or exceed its authority under the Constitution. Furthermore, he stated that there was no evidence of any intent by Congress to use this tax as a means of regulation outside their constitutionally granted power. Therefore, according to Justice Stone, since this tax did neither of these things and fell squarely within congressional taxing power outlined in Article I Section 8 of the Constitution - which gives Congress wide latitude in choosing sources of revenue - it should have been upheld by the court.