In the United States v. Stahl case of 1893, the Supreme Court ruled on a matter involving customs duties. The defendant, Stahl, had imported iron bands into the U.S., which were used for baling cotton and hay. At that time, there was an existing tariff law stating that "iron or steel bands" would be subject to a duty rate of one cent per pound while other types of iron or steel products were taxed at different rates. The collector imposed this higher rate on Stahl's importation but he protested arguing his goods should have been classified under another category with lower tax rates as they weren't specifically designed for cotton bales. The Supreme Court sided with Stahl in its decision by interpreting that Congress intended to apply the term "bands" only to those items specially made and used for binding cotton bales rather than any band-like item made from iron or steel regardless of their use. Therefore, it held that these imported items did not fall within this specific classification and thus should not be subjected to such high-duty charges.

The dissenting opinion in the United States v. Stahl case argued that the majority's decision to uphold a tax on income derived from property was unconstitutional. The dissenters believed that this tax violated the Constitution's requirement for direct taxes to be apportioned among states according to their population, as outlined in Article I, Section 9. They contended that an income tax is essentially a direct tax because it directly affects individuals and cannot be shifted onto others like indirect taxes can. Therefore, they asserted that such a tax should have been apportioned among states based on population rather than being levied uniformly across all taxpayers regardless of where they live or how much property they own. This view held by the minority justices reflected their belief in strict adherence to constitutional provisions and limitations placed upon federal taxation powers.