In the United States v. Seaboard Air Line Railroad Co., 1959, the Supreme Court ruled on a dispute between a railroad company and the federal government over tax deductions. The Seaboard Air Line Railroad Company had claimed depreciation deductions for its property that was used in interstate commerce during World War II when it was under federal control. The Internal Revenue Service (IRS) denied these claims, arguing that since the property wasn't in use by the company at this time, they were not entitled to claim any depreciation. However, Seaboard argued that despite being under federal control during wartime operations from 1942-1946, they should still be allowed to claim these deductions as their assets were depreciating due to wear and tear regardless of who controlled them. The case reached the Supreme Court which sided with Seaboard's argument stating that even though properties were operated by U.S Government during war times; it doesn’t mean those properties didn’t suffer from wear and tear or exhaustion while serving public purpose hence allowing companies like seaboard air line railroad co., to avail benefits of such losses through tax deduction.

The dissenting opinion in the United States v. Seaboard Air Line Railroad Co., 1959 case argued that the majority's decision was inconsistent with previous rulings and interpretations of the Interstate Commerce Act. The dissenters believed that by allowing a railroad company to be held liable for damages caused during interstate commerce, even when they were not at fault or negligent, would place an unfair burden on these companies. They contended that this interpretation could potentially lead to unjust outcomes where railroads are forced to pay for damages they did not cause or could have prevented. Furthermore, it was suggested that such a ruling might discourage investment in railway infrastructure due to increased financial risk associated with potential liability claims.