In the case of Rex Trailer Co., Inc. v. United States in 1955, the Supreme Court ruled on a dispute regarding tax deductions for business expenses. The plaintiff, Rex Trailer Company, had purchased war surplus property from the government and then leased it back to them during World War II. After the war ended, they sold this equipment at a loss and claimed these losses as tax deductions under Section 117(j) of Internal Revenue Code which allows such claims if properties are used directly in trade or business operations. The IRS denied their claim arguing that leasing did not constitute "use" within meaning of section 117(j). This led to litigation with lower courts ruling in favor of Rex Trailer Co., stating that leasing was indeed considered use under section 117(j). However, upon reaching Supreme Court level review, it was held that merely leasing out property does not qualify as 'use' within context of Section 117 (j), thus reversing lower court's decision. Therefore, Rex Trailer Co.'s claim for deduction based on losses incurred from sale after lease were disallowed.

The dissenting opinion in the case of Rex Trailer Co., Inc. v. United States argued that the majority's decision to uphold a tax on trailers used for long-term residential purposes was inconsistent with previous rulings and interpretations of the law. The dissent contended that these types of trailers should be considered homes, not vehicles, and therefore exempt from federal highway use taxes under existing legislation. They pointed out that many people live in such trailers permanently or semi-permanently, making them more akin to houses than cars or trucks. Furthermore, they noted that these trailers are often parked indefinitely and do not contribute significantly to road wear-and-tear like traditional motor vehicles do - one of the primary justifications for imposing highway use taxes in the first place.