In the United States v. Joseph A. Holpuch Co., 1945, the U.S Supreme Court dealt with a case concerning tax law and its application to property sold under contract for deed. The respondent, Joseph A. Holpuch Co., had sold several properties on installment contracts where buyers made monthly payments but did not receive deeds until full payment was completed. The company reported these sales as capital gains in their income tax returns, which were taxed at a lower rate than ordinary income. The Internal Revenue Service (IRS) disagreed with this classification and assessed additional taxes against the company arguing that such transactions should be treated as ordinary income since legal title remained with the seller until full payment was made by buyer. However, upon appeal to higher courts including Supreme Court of United States it was held that despite retaining legal title till complete payment is done by buyer; economic benefits and burdens of ownership transferred substantially to buyer from time they entered into contract itself hence treating them as capital gain rather than ordinary income is justified.

In the dissenting opinion for United States v. Joseph A. Holpuch Co., Justice Robert H. Jackson disagreed with the majority's ruling that a contract between the government and a private company could be altered without consent from both parties involved, based on changes in circumstances or conditions not anticipated at the time of agreement. He argued that this interpretation undermined fundamental principles of contract law and set a dangerous precedent for future cases involving contractual disputes with governmental entities. Furthermore, he contended that it was unfair to hold private companies accountable for unforeseen events beyond their control, such as war-related disruptions affecting material costs or availability - factors which were central to this case where Holpuch Co.'s ability to fulfill its obligations under an agreed construction project had been severely impacted by World War II exigencies.