In the case of Worth Brothers Company v. Lederer, Collector of Internal Revenue for the First District of Pennsylvania (1919), the U.S Supreme Court was tasked with determining whether a tax imposed on excess profits during World War I was constitutional. The Worth Brothers Company argued that this tax violated their Fifth Amendment rights by depriving them of property without due process and taking their property for public use without just compensation. However, the court ruled in favor of Lederer, stating that Congress had broad powers to levy taxes under Article 1 Section 8 Clause 1 of the Constitution and these powers were not limited by other provisions within it unless explicitly stated otherwise. Therefore, they concluded that there was no violation against any constitutional right as claimed by Worth Brothers Company because taxation is an inherent power granted to Congress which does not require compensation or follow traditional due process procedures when levied fairly among taxpayers.

In the dissenting opinion for Worth Brothers Company v. Lederer, Justice Oliver Wendell Holmes Jr. argued that the majority's interpretation of the law was incorrect and overly narrow. He contended that Congress intended to tax all income from whatever source derived, including dividends received by a corporation from another company in which it held stock. In his view, this broad interpretation was consistent with both the language and purpose of the Sixteenth Amendment to levy taxes on incomes without apportionment among states based on population size. Holmes also disagreed with the majority's reliance on previous court decisions interpreting similar statutes differently because those cases were decided before passage of this amendment and thus did not take its broader taxing power into account.