In Tutton, Collector v. Viti & Another, the United States Supreme Court was asked to decide whether a tax imposed by the United States on imported goods was constitutional. The tax was imposed on imported goods that were intended for sale in the United States. The Court held that the tax was constitutional, as it was a valid exercise of the power of Congress to impose taxes on imported goods. The Court noted that the tax was imposed on imported goods, and not on the persons importing them. The Court also noted that the tax was imposed on the goods themselves, and not on the persons importing them. The Court further noted that the tax was imposed on the goods for the purpose of raising revenue, and not for the purpose of regulating the importation of goods. The Court concluded that the tax was a valid exercise of the power of Congress to impose taxes on imported goods, and that it was not an unconstitutional exercise of the power of Congress to regulate commerce. The Court held that the tax was constitutional, and that it was not an unconstitutional exercise of the power of Congress to regulate commerce.

In Tutton, Collector v. Viti & Another, the Supreme Court was asked to decide whether a tax imposed by Congress on imported goods was constitutional. The majority opinion held that it was not and struck down the law as unconstitutional. However, Justice Field dissented from this ruling and argued that Congress had the power to impose taxes on imports under its authority granted in Article I of the Constitution. He further noted that while there may be some practical difficulties with implementing such a tax system, these issues should not prevent Congress from exercising its powers when they are clearly authorized by the Constitution. Ultimately, he concluded that if any part of an act is valid then it must stand regardless of other parts being invalidated due to their unconstitutionality or impracticality.