The National Railroad Passenger Corporation v. Atchison, Topeka & Santa Fe Railway Co., et al., 1984 was a case that revolved around the interpretation of the Rail Passenger Service Act of 1970. The Supreme Court ruled in favor of the National Railroad Passenger Corporation (Amtrak), stating that it had no obligation to pay state and local taxes on rail properties used for interstate passenger service which were leased from other railroad companies. This decision overturned an earlier ruling by California courts, which held Amtrak liable for these taxes under its lease agreements with several railway companies including Atchison, Topeka & Santa Fe Railway Co. The Supreme Court's judgment hinged on their interpretation that Congress intended to exempt Amtrak from such tax burdens when they established it as a quasi-public entity through the aforementioned act.

In the dissenting opinion for the National Railroad Passenger Corporation v. Atchison, Topeka & Santa Fe Railway Co., it was argued that Amtrak should be considered a private entity rather than a public one. The dissenters believed that Congress intended to create an independent, profit-making corporation when they established Amtrak in 1970 and did not intend for it to function as part of the government. They pointed out that while Amtrak does receive federal subsidies, so do many other businesses which are not considered governmental entities. Furthermore, they noted that most of its stock is privately held and its board members are primarily private citizens who can be removed by their fellow directors rather than by any government official or body. Therefore, according to this view, because Amtrak operates more like a private business than a public agency with regard to its financial operations and governance structure; thus it should have been treated as such in this case.