The United States Supreme Court case, UNITED STATES v. TOWNSHIP OF MUSKEGON et al., 1957, revolved around a dispute over tax jurisdiction on federally owned land leased to private entities for commercial use. The federal government had acquired lands within Muskegon Township in Michigan during World War II and subsequently leased them to private corporations. The township sought to levy property taxes on the lessees' interests in these properties, which the United States contested arguing that it was immune from such taxation under the Supremacy Clause of the Constitution. The Supreme Court ruled against the U.S., holding that while federal property itself is immune from state and local taxation, this immunity does not extend to private parties who have an interest or are conducting business on said property. Therefore, Muskegon Township could indeed impose its tax upon those leasehold interests held by non-governmental entities operating commercially on federally-owned land within its jurisdiction.

In the dissenting opinion for United States v. Township of Muskegon et al., Justice Brennan disagreed with the majority's decision that a federal enclave, in this case a military installation, was not exempt from local property taxes. He argued that when the Federal Government acquired exclusive jurisdiction over an area within a state, it became immune to state taxation unless Congress explicitly waived this immunity. In his view, there was no such waiver in this case and therefore the imposition of local property taxes on federally-owned housing units violated constitutional principles of intergovernmental tax immunity. Furthermore, he contended that even if there had been some form of congressional consent to taxation by implication through legislation permitting private residential development on federal land - as suggested by the majority - such implied consent should be narrowly construed and not extended beyond its express terms or necessary implications.