The United States Supreme Court case of United States v. Archibald McNeil & Sons Co., Inc., 1924, revolved around a dispute over the interpretation of tariff laws. The defendant, Archibald McNeil & Sons Co., imported iron ore into the U.S and was charged with duties under paragraph 140 of the Tariff Act of October 3rd, 1913. However, they argued that their imports should have been classified under paragraph 122 which would result in lower duty charges. The main issue at hand was whether or not these ores were "manganiferous" as defined by Paragraphs 122 and/or Paragraphs140 to determine appropriate tariffs for importation.The court ruled in favor of the government stating that according to chemical analysis provided by both parties it is clear that manganese is present but not in commercially valuable quantities hence cannot be considered manganiferous ores within meaning and intent of tariff act.

The dissenting opinion in the case of United States v. Archibald McNeil & Sons Co., Inc., argued that the majority's decision to uphold a tax assessment against the company was incorrect. The dissent contended that, under existing law and precedent, a corporation could not be taxed on income derived from property owned by its shareholders unless it had control over or received benefit from such property. In this case, they believed that there was no evidence to suggest that Archibald McNeil & Sons Co., Inc. controlled or benefited from properties owned by its shareholders; therefore, taxing them based on these assets violated established legal principles regarding corporate taxation. They also disagreed with the majority's interpretation of "income" for tax purposes and felt their ruling expanded government power beyond acceptable limits.