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According to a recently released report by the Congressional Research Service , property owners won regulatory takings cases more often than not in 1990 . In the case of San Remo Hotel v. San Francisco , hotel owners argued that the Court 's rules about the timing of property claims deprived them of their ability to have their case heard in federal court . Before early 2000 , brand owners internalized the cost of the recycling fees . In the South , plantation owners needed slave ' hands ' in great part because the machinery to plant and pick cotton did not exist ; indeed , American tenant farming has disappeared over the past two generations largely because new machinery was introduced to replace the labor of ' freed ' black sharecroppers . Because so many of them file their business income on personal income tax forms , when the President cut marginal rates , small-business owners felt great relief .