In the case of United States v. Commonwealth Title Insurance and Trust Company, 1903, the U.S. Supreme Court dealt with a dispute over tax liability on bonds issued by the District of Columbia under an act passed in 1870 to fund public improvements. The Commonwealth Title Insurance and Trust Company held some of these bonds but refused to pay taxes on them, arguing that they were exempt from taxation as per their understanding of the original legislation authorizing their issuance. However, this interpretation was disputed by the government which insisted that such exemption did not exist or had been subsequently repealed. The court sided with the government's position after examining both arguments carefully. It ruled that while there was indeed a provision for tax exemption in one section of law related to these bonds, another section explicitly stated all exemptions would cease if certain conditions were met - specifically if any amendments were made to it later on. Since Congress had indeed amended this law several times post-1871 (the year when these specific provisions came into effect), including once where it removed all exemptions for federal securities from local taxation altogether; therefore no valid claim could be made for continued tax-exemption based upon initial terms alone.

In the dissenting opinion for United States v. Commonwealth Title Insurance and Trust Company, it was argued that the majority's decision to allow a federal tax lien on property held by a trust company in Pennsylvania was incorrect. The dissenting justices believed that under state law, the trust company did not have sufficient ownership of the property to be subject to a federal tax lien. They contended that because the funds were being held in trust for individual depositors, they should not be considered part of the assets of the bank itself. Therefore, these funds should not be subjected to seizure by federal authorities seeking payment for taxes owed by Commonwealth Title Insurance and Trust Company. This interpretation would protect depositor’s rights and maintain faith in financial institutions while also respecting states' rights over their own banking regulations.