In the case of United States v. L.P. & J.A. Smith, 1920, the Supreme Court dealt with a dispute over import duties on raw sugar from Cuba into the U.S., specifically whether or not certain sugars were dutiable under paragraph 181 of the Tariff Act of October 3rd, 1913. The defendants argued that their imported sugars were "sugars above number sixteen Dutch standard in color" and thus exempted from duty according to a commercial agreement between US and Cuba signed in December 11th,1902 which was still effective at that time despite changes made by later tariff acts including one passed in October 3rd ,1913 . However,the government contended that these sugars fell within paragraph number181 as they had been refined beyond this point before being exported to America.The court ruled against L.P.&J.A Smith stating that it is clear from reading both agreements together (the commercial agreement and tariff act)that only those sugars are free which have not been advanced beyond No16 D.S.in color by any process of refinery i.e.,raw sugar while all others would be subject to duty regardless if they originated from Cuba or elsewhere.This decision upheld an earlier ruling by Customs Appraiser who imposed duties on such imports.

The dissenting opinion in the case of United States v. L.P. & J.A. Smith argued that the majority's decision to uphold a tax on inherited property was unconstitutional, as it violated the principle of uniformity required by Article I, Section 8 of the Constitution. The dissent contended that this tax unfairly targeted certain individuals based solely on their receipt of an inheritance and not on any measure related to their ability to pay or other equitable considerations. Furthermore, they believed that such a direct tax should be apportioned among states according to population rather than being levied uniformly across all inheritances regardless of location or size - something which this law did not do.