In United States v. The Commissioner, the Supreme Court was asked to decide whether a tax imposed by Congress on certain incomes was constitutional. The court held that it was not, finding that the power of taxation did not extend to such income and thus could not be used as a means of raising revenue for the government. Furthermore, they found that if Congress were allowed to impose taxes on this type of income then it would amount to an unconstitutional taking without due process or compensation from those affected by it. In conclusion, the court ruled in favor of The Commissioner and declared the tax unconstitutional.

In United States v. The Commissioner, the Supreme Court was tasked with determining whether a tax imposed on income from certain bonds issued by the state of Tennessee was constitutional. Justice Field delivered a dissenting opinion in which he argued that Congress did not have the power to impose such taxes under Article I, Section 8 of the Constitution. He reasoned that this section only gave Congress authority to lay and collect taxes for specific purposes related to its enumerated powers; it did not give them general taxing power over all sources of income or property within their jurisdiction. Furthermore, he noted that if Congress had been given such broad authority then they could potentially interfere with states’ rights and sovereignty by imposing taxes on any source of revenue within their borders without limitation or restriction. As such, Justice Field concluded that this particular tax was unconstitutional as it exceeded Congressional authority granted under Article I, Section 8 and violated states’ rights protected by other provisions in the Constitution.