In the Southern Realty Investment Company v. Walker case of 1908, the U.S Supreme Court ruled in favor of Walker, upholding a lower court's decision that he was not liable for taxes on land purchased from Southern Realty Investment Company. The company had sold him property with an agreement to pay all taxes until the title passed to Walker; however, it failed to do so and argued that responsibility should fall on Walker as he held equitable title. The court disagreed stating that legal ownership remained with Southern Realty until full payment was made by Mr.Walker and thus they were responsible for tax payments during this period.

The dissenting opinion in the case of Southern Realty Investment Company v. Walker argued that the majority's decision was a departure from established legal principles regarding property rights and taxation. The dissent contended that under Mississippi law, tax sales did not extinguish pre-existing liens on properties unless those lienholders were properly notified and given an opportunity to protect their interests. In this case, they believed that the plaintiff had a valid mortgage lien on the property at issue which should have survived any subsequent tax sale due to lack of proper notification about such sale. They also disagreed with the majority's interpretation of state laws governing redemption rights after a tax sale, arguing it unfairly deprived lienholders like Southern Realty Investment Company of their rightful claims without just compensation or due process.