The Wheeler Lumber Bridge and Supply Company of Des Moines, Iowa v. United States case in 1929 revolved around the issue of whether a tax imposed on the manufacture, sale or use of filled milk was constitutional. The Supreme Court ruled that it was indeed constitutional to impose such a tax. Filled milk is defined as any milk product where non-milk fat has been substituted for natural milk fat; this process often results in products cheaper than pure dairy items but with similar taste and texture. The court held that Congress had the power to prevent deception in sales by imposing taxes on these types of products under its taxing powers granted by Article I, Section 8 of the Constitution.

In the dissenting opinion for Wheeler Lumber Bridge and Supply Company v. United States, Justice Stone argued that the majority's decision to uphold a tax on wholesale sales of lumber was inconsistent with previous rulings by the Court. He contended that this case was not about whether Congress had power to impose such a tax but rather if it had done so in this instance. The language used in drafting the Revenue Act of 1921 did not clearly indicate an intention to levy taxes on transactions like those carried out by Wheeler Lumber Bridge and Supply Company, according to Justice Stone. Therefore, he believed that ambiguity should be resolved against imposition of taxation without clear legislative intent.