In the case of Tide Water Oil Company v. United States, 1897, the Supreme Court ruled on a dispute involving oil import duties. The Tide Water Oil Company imported crude petroleum from Russia and argued that it should be classified as "crude mineral oil" under tariff laws, which would result in lower import taxes. However, the U.S government contended that it should be categorized as "petroleum," leading to higher tariffs. The court sided with the government's interpretation of tariff classifications for petroleum imports based on historical context and legislative intent behind those laws at that time. Therefore, they held that Russian crude petroleum was subject to higher duty rates than what Tide Water Oil Company had claimed.

The dissenting opinion in the case of Tide Water Oil Company v. United States argued that the majority's decision to uphold a tax on petroleum exports was inconsistent with previous rulings and constitutional principles. The dissent contended that this tax violated both the Export Clause, which prohibits taxes or duties on exports, and the Uniformity Clause, which requires all duties, imposts and excises to be uniform throughout the U.S. They believed that by upholding this tax, they were allowing Congress an unrestricted power of taxation over exports contrary to what framers intended when drafting these clauses in Constitution. Furthermore, they expressed concern about potential economic consequences if such taxes were allowed as it could discourage exportation activities vital for national economy.