In the 1932 case of Burnet, Commissioner of Internal Revenue v. A.T. Jergins Trust, the U.S Supreme Court ruled on a matter involving income tax and oil property rights. The A.T. Jergins Trust had purchased oil properties in California and later sold them at a profit but did not include this gain in their gross income for taxation purposes as they believed it was capital gain rather than taxable income under existing laws at that time (Revenue Act of 1921). However, the Commissioner of Internal Revenue disagreed with this interpretation and assessed additional taxes against the trust based on these profits from sale. The court sided with the commissioner's view that such gains were indeed taxable under Section 206(a) of Revenue Act which stated that any gains derived from sales or dealings in property should be included in gross income unless explicitly exempted by law. Therefore, even though there was no explicit provision dealing with oil properties specifically within this act, its general principle applied to all types of properties including those related to oil extraction activities.

In the dissenting opinion for Burnet, Commissioner of Internal Revenue v. A.T. Jergins Trust, Justice Stone argued that the majority's decision was inconsistent with previous rulings and principles of tax law. He contended that a trust should not be treated as an association taxable as a corporation simply because it has some characteristics similar to those of corporations. Instead, he believed that trusts should only be taxed as corporations if they are used primarily for business purposes rather than merely holding and managing property or investments - which is what he thought was happening in this case. Furthermore, Justice Stone disagreed with the majority's interpretation of "associations" under federal tax law; he maintained that Congress intended to include only entities organized for profit-making activities within its scope.