In the case of Mine Safety Appliances Co. v. Forrestal, 1945, the United States Supreme Court ruled in favor of Mine Safety Appliances Company (MSA). The dispute arose when MSA was denied a refund for excess profits taxes it had paid during World War II under an incorrect interpretation of tax law by James Forrestal, then Secretary of Defense. MSA argued that they were entitled to a tax benefit due to their contribution towards war production efforts and should not be penalized with excessive profit taxation. The court agreed with MSA's argument and held that companies contributing to war production could claim deductions on their excess profits taxes based on their investment in facilities used for war production purposes.

In the dissenting opinion for Mine Safety Appliances Co. v. Forrestal, Justice Frankfurter argued that the majority's decision was an overreach of judicial power and a misinterpretation of Congressional intent. He contended that Congress had intended to give broad powers to administrative agencies like the War Production Board (WPB) during times of war, including price-setting authority. The WPB's interpretation of its own mandate should be given deference unless it is clearly unreasonable or in violation of law - which he did not believe was the case here. Furthermore, he believed that courts should avoid interfering with wartime measures unless absolutely necessary due to their lack of expertise in military matters compared to executive agencies tasked with managing war efforts.