In the United States v. Ingram case of 1898, the Supreme Court ruled on a matter involving taxation and property rights. The defendant, Ingram, was a cotton broker who had purchased cotton for his clients but stored it in public warehouses under his own name until he could transfer it to them. The government argued that since the cotton was technically in Ingram's possession during this time period, he should be liable for taxes on it as personal property. However, the court disagreed with this interpretation. They held that although Ingram did have temporary control over the goods due to logistical reasons related to their purchase and delivery process, they were not actually part of his taxable estate because they belonged to his customers from whom he had received payment already or would receive soon after delivering their purchases.

The dissenting opinion in the United States v. Ingram case argued that the majority's decision was incorrect because it failed to consider the nature of a tax on distilled spirits as an excise, not a direct tax. The dissenting justices believed that this distinction was crucial and should have been recognized by the court. They contended that if such taxes were considered direct, they would need to be apportioned among states according to their population, which is impractical and contrary to long-standing practice. Furthermore, they disagreed with the majority's interpretation of what constitutes "export" under U.S law; arguing instead for a broader definition encompassing any shipment from one state or territory within U.S jurisdiction to another outside it - regardless of whether it crosses international waters or not.