In the case of Tyng v. Grinnell, Collector, the Supreme Court of the United States was asked to decide whether a tax imposed by the United States on the sale of certain goods was constitutional. The plaintiff, Tyng, argued that the tax was unconstitutional because it was a direct tax, which the Constitution prohibited. The defendant, Grinnell, argued that the tax was an indirect tax, which was allowed under the Constitution. The Supreme Court held that the tax was an indirect tax, and therefore was constitutional. The Court reasoned that the tax was imposed on the sale of goods, and not on the person or property of the taxpayer. Therefore, the tax was not a direct tax, and was allowed under the Constitution. The Court also held that the tax was not a violation of the due process clause of the Constitution. The Court reasoned that the tax was imposed on the sale of goods, and not on the person or property of the taxpayer. Therefore, the tax was not a violation of the due process clause. In conclusion, the Supreme Court held that the tax imposed by the United States on the sale of certain goods was constitutional, and did not violate the due process clause of the Constitution.

In the case of Tyng v. Grinnell, Collector, a majority opinion was issued by the Supreme Court that held in favor of the defendant. The dissenting opinion argued that Congress had not intended for taxes to be imposed on property owned by an individual prior to their death and passed onto another person through inheritance or will. Furthermore, it was contended that such taxation would amount to double taxation as those who received inherited property were already taxed on any income they earned from said property while alive. As such, it was concluded that this type of tax should not have been applied in this particular instance and thus reversed the decision made by lower courts which favored the defendant collector.