In Combs v. United States (1971), the Supreme Court ruled on a case involving the interpretation of tax laws related to mining rights. The petitioner, Combs, had leased land for coal mining and then subleased these rights to another company in exchange for royalties based on the amount of coal mined. When filing his taxes, he claimed deductions for depletion allowances - a provision that allows miners to account for the reduction in their mine's value as resources are extracted - arguing that he was entitled to them because he retained an economic interest in the coal through his royalty agreement. However, both lower courts denied this claim stating that only those who have capital investment at risk can claim such deductions. The Supreme Court reversed these decisions with Justice Hugo Black delivering its opinion. It held that under Section 611 of Internal Revenue Code, any person having an economic interest in mineral deposits is eligible for depletion allowance regardless if they bear any risk or not; thus allowing Combs' deduction claims since his income was dependent upon production.

In the dissenting opinion for Combs v. United States, it was argued that the majority's decision to uphold Combs' conviction under a federal statute prohibiting threats against the President was incorrect. The dissenting justices believed that there wasn't enough evidence to prove beyond reasonable doubt that Combs had intended his statement as a real threat towards then-President Lyndon B. Johnson, rather than just an expression of political hyperbole or crude humor. They also expressed concerns about potential First Amendment implications and warned against criminalizing speech based on its content without clear proof of malicious intent.