In the case of United States v. Resler, the Supreme Court addressed whether a trucking company was liable for unpaid taxes under Section 345 of the Revenue Act of 1926. The government argued that Resler Truck Line and Brady Truck Line were essentially one business entity operating under two names, thus making them jointly responsible for any tax liabilities. However, Mr. Resler contended that they were separate entities with distinct operations and should be treated as such for taxation purposes. The court ruled in favor of the U.S Government stating that despite having different names and some differences in operation, both businesses had substantial similarities including shared management by Mr.Resler himself which indicated they operated as a single unit or enterprise; hence joint liability applied to them regarding their tax obligations. This decision set an important precedent on how courts determine if seemingly separate business entities are actually part of one larger organization when it comes to financial responsibilities like paying taxes.

The dissenting opinion in the United States v. Resler case argued that the majority's decision was an overreach of federal power and a misinterpretation of interstate commerce regulations. The dissent contended that while Congress has authority to regulate interstate commerce, it does not have unlimited power to control all aspects of business operations merely because they are involved in such trade. They believed that the transportation company, Resler Truck Line, operating within state boundaries should be subject primarily to state laws rather than federal ones unless their activities directly affected other states or interfered with free flow of trade across borders. Furthermore, they disagreed with imposing penalties on businesses for failing to comply with certain administrative procedures if these did not harm public interest or obstruct commerce between states.