In the 1984 case of Tiffany Fine Arts, Inc. v. United States, the Supreme Court ruled on a dispute involving customs duties and imported art pieces. The plaintiffs were importers who had purchased artwork from foreign artists or their estates with an agreement to resell them in the U.S., but claimed that they should only be required to pay duty on their purchase price rather than the higher appraised value at time of entry into America as determined by Customs officials. They argued this was unfair because it did not reflect their actual economic gain from these transactions. The court disagreed with this argument and upheld that under Section 402 of Tariff Act (1930), dutiable value is based upon "the transaction value" which means "the price actually paid or payable for merchandise when sold for exportation to US". This includes any subsequent enhancements made prior to importation regardless if importer has no financial interest in those improvements. Therefore, even though Tiffany Fine Arts didn't directly benefit financially from increased valuation due to artist's death or other factors after initial purchase abroad but before resale domestically, they still owed customs duties based on enhanced values at point of entry into U.S., not just what they originally paid.

In the dissenting opinion for Tiffany Fine Arts, Inc. v. United States et al., Justice Stevens argued that the majority's decision to allow an in rem forfeiture of a painting imported into the country illegally was inconsistent with both statutory law and constitutional principles. He contended that there was no clear evidence of congressional intent to permit such forfeitures under customs laws, and he criticized the majority for interpreting ambiguous statutes in favor of forfeiture rather than against it as precedent suggests they should have done. Furthermore, he believed this interpretation violated due process rights by punishing innocent owners who may not have known about any illegal activity associated with their property. In his view, only those who were complicit or negligent regarding illicit importation should face penalties like forfeiture.