In the United States v. Garlinger case of 1897, the Supreme Court ruled on a dispute involving property rights and taxation. The defendant, Garlinger, was a landowner in Kansas who had leased his land to an oil company for exploration and extraction purposes. He argued that he should not be taxed on royalties received from this lease because they were derived from real estate located in another state (Pennsylvania). However, the government contended that these royalties constituted income and were therefore subject to federal tax laws. The Supreme Court sided with the government's argument. It held that while real estate itself could not be taxed by states where it wasn't physically located, income generated from such properties - including royalty payments - could indeed be subjected to taxation under federal law regardless of where the property is situated or where its owner resides. This ruling established important precedents regarding interstate commerce and taxation laws within U.S., affirming that individuals cannot evade taxes simply by deriving their incomes from out-of-state sources.

The dissenting opinion in the United States v. Garlinger case argued that the majority's interpretation of the law was incorrect and overly broad. The dissenters believed that Congress did not intend to include all types of property under its tax laws, but rather only those properties which were specifically mentioned in the statute. They also disagreed with the majority's view on what constitutes a "sale" for taxation purposes, arguing that it should be interpreted more narrowly to exclude certain transactions such as exchanges or transfers without monetary consideration. Furthermore, they contended that even if these transactions were considered sales, they should not be taxed because they do not result in any gain or profit for either party involved. Thus, according to this viewpoint, Mr.Garlinger’s transfer of his stock holdings into a trust shouldn't have been taxable since he didn’t receive any financial benefit from it.