 McReynolds further argued that none of the cases cited by the majority supported the majority's opinion, as they were decided narrowly and the facts in each case were so unlike the facts in the instant case that they were inapplicable.The dissent agreed that it is often difficult to determine whether a tax is laid on a company's general operations (which is valid) or on the specific transaction with the federal government (which is not valid), the majority's emphasis on the independent contractor nature of the company was misplaced since every private company is an independent contractor to the federal government.The government had argued that the tax was nondiscriminatory, and so did not unduly burden the federal government more than any buyer of goods and services.