In the 1914 case Pennsylvania Company v. United States, the Supreme Court was asked to determine whether a tax imposed by Congress on corporations' net income violated constitutional principles of uniformity and apportionment among states. The Pennsylvania Company argued that since its income derived from various sources including real estate, personal property, and interstate commerce activities across multiple states, it should not be subject to this federal tax. However, the court upheld the constitutionality of the corporate excise tax law enacted in 1909 which levied taxes on corporations’ net incomes regardless of their source or location. The court ruled that such taxation did not violate either uniformity clause as all corporations were taxed at an equal rate nor apportionment rule because it was an excise (indirect) rather than direct tax which required apportionment among states according to population.

The dissenting opinion in the Pennsylvania Company v. United States case argued that the Interstate Commerce Commission (ICC) did not have the authority to regulate or control stock and bond issues of railroads, as it was beyond its constitutional powers. The dissenters believed that such regulation would interfere with private property rights without due process of law, violating the Fifth Amendment. They also contended that Congress could not delegate legislative power to an administrative body like ICC without clear guidelines or standards for action, which they felt was lacking in this instance. Furthermore, they expressed concern about potential misuse of such broad regulatory power by ICC and warned against setting a dangerous precedent where administrative bodies could exercise unchecked discretion over private businesses' financial decisions.