In the case of Nassau Smelting & Refining Works, Ltd. v. United States (1924), the U.S Supreme Court ruled in favor of the United States government regarding a dispute over customs duties on imported copper materials. The Nassau Smelting & Refining Works, Ltd., a Canadian company, argued that they should not have to pay full duty rates for their imports because some parts were made from previously exported American scrap metal and thus should be exempt under existing trade laws at that time which allowed for drawback claims - refunds on import taxes when goods are re-exported or used as raw material in manufacturing exported products. However, the court held that since there was no proof provided by Nassau showing exactly how much of their product was made from this recycled American scrap metal versus new foreign materials, it would be impossible to accurately determine what percentage of their imports should qualify for reduced duty rates. Therefore, all imported items were subject to full customs duties regardless if part or all components came from previously taxed American exports.

In the dissenting opinion for Nassau Smelting & Refining Works, Ltd. v. United States, it was argued that the majority's interpretation of the Tariff Act of 1913 was incorrect and overly broad. The dissent contended that Congress did not intend to impose a duty on scrap metal imports because they were not "articles" as defined by the law but rather raw materials used in manufacturing processes. Furthermore, it was suggested that if Congress had intended to tax such items, it would have done so explicitly in clear language within the legislation itself instead of leaving room for ambiguity or interpretation by courts or administrative agencies. It also pointed out potential negative economic implications from imposing duties on these types of goods which could lead to increased costs for manufacturers and consumers alike while potentially stifling innovation and competition within certain industries.