In the case of United States v. M. Rice & Company et al., 1921, the Supreme Court ruled on a dispute concerning customs duties imposed on imported rice. The U.S government argued that M. Rice & Co had underpaid their duties by misclassifying their imports as "cleaned" instead of "uncleaned" rice, which carried a higher tariff rate according to the Tariff Act of 1913. The company contended that they were not liable for additional payments because they had correctly classified their goods based on industry standards and practices at the time. The court sided with the government, stating that in matters related to tariffs and trade regulations, it is Congress's definitions - rather than those used by traders or commercial entities - that are legally binding when interpreting laws such as these ones about import taxes/duties etcetera; therefore any ambiguity should be resolved in favor of domestic industries (i.e., towards protectionism). This decision upheld an earlier ruling from a lower court which also found against M.Rice&Co.

In the dissenting opinion of United States v. M. Rice & Company et al., 1921, it was argued that the majority's decision to uphold a tax on rice millers contradicted previous rulings and principles of taxation established by the Supreme Court. The dissenting justices believed that this tax was not an excise but rather a direct tax on property or income, which would require apportionment among states according to their population as mandated by Article I, Section 9 of the Constitution. They contended that if such taxes were allowed without apportionment, it could lead to arbitrary and potentially oppressive taxation practices in future cases. Furthermore, they expressed concern about potential negative impacts on businesses and industries due to unpredictable changes in taxation laws based upon shifting interpretations by different courts or administrations.