The U.S. Supreme Court case Doyle v. Mitchell Brothers Company in 1917 revolved around the issue of income tax and its application to a company's gross receipts from timber sales. The Mitchell Brothers Company, a lumber business, argued that their entire gross receipts should not be taxed as income under the Sixteenth Amendment because it included capital derived from the depletion of their timber resources - an asset which was not replenished or compensated for by these sales. The court ruled in favor of Mitchell Brothers, stating that only net profits could be considered taxable income, not total revenue generated by selling assets (in this case, trees). This decision established an important precedent regarding how businesses' incomes were assessed for taxation purposes.

The dissenting opinion in the case of Doyle v. Mitchell Brothers Company argued that income should be defined as a gain or profit derived from capital, labor, or both combined. The dissenters believed that the majority's interpretation of income was too broad and went beyond what was intended by Congress when it enacted the 16th Amendment to allow for an income tax. They contended that not all receipts could be considered taxable income under this definition; only those amounts which represented clear gains or profits should be taxed. This would exclude items such as stock dividends, which were seen more as a redistribution of company assets rather than new wealth creation for shareholders.