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In the case of Sonn v. Magone in 1895, the United States Supreme Court ruled on a dispute involving import duties. The plaintiff, Sonn, imported iron bands used for sugar boxes from Germany and argued that they should be classified as "iron bands for machinery," which would result in lower import duties under U.S customs law at the time. However, Collector of Customs Magone categorized them as "hoop iron" or "band iron", subjecting them to higher tariffs. The court sided with Magone's classification and upheld his decision to impose higher duty rates on these imports based on their physical characteristics rather than their intended use after entering into commerce within the country. This ruling reinforced that it was not only an item’s specific purpose but also its form and material composition that determined its categorization under tariff laws.
In the dissenting opinion for SONN v. MAGONE, Justice Brewer argued that the majority's interpretation of tariff laws was incorrect and inconsistent with previous court decisions. He contended that a tax on imported goods should be based on their market value at the time of exportation, not when they were ordered or contracted for purchase. According to him, this would prevent potential manipulation by importers who could artificially lower prices by ordering goods far in advance before actual shipment occurs. Furthermore, he pointed out inconsistencies within the majority’s decision itself - while it held that contract price is not conclusive evidence of dutiable value if made in good faith and without fraud or collusion; it also suggested such contracts are irrelevant to determining dutiable values which contradicted its own ruling.