The U.S. Supreme Court case Indian Territory Illuminating Oil Company v. State of Oklahoma in 1915 revolved around the issue of taxation on oil and gas leases by the state government. The plaintiff, Indian Territory Illuminating Oil Company, held leases from members of an Osage tribe for mining purposes on allotted lands within Oklahoma's borders. They argued that these lands were exempt from state taxation under federal law as they were part of a Native American reservation and thus fell under federal jurisdiction rather than state jurisdiction. However, the court ruled against them stating that while Congress had indeed granted certain tax exemptions to tribal land allotments, this did not extend to commercial operations conducted upon those lands by non-tribal entities or individuals such as corporations like ITIO Co., which was seeking profit through mineral extraction activities thereon. Therefore, it upheld Oklahoma’s right to impose taxes on oil and gas extracted from these leased tribal lands despite their status as federally recognized reservations because such business ventures weren't covered under existing congressional tax exemption provisions for native tribes.

The dissenting opinion in the case of Indian Territory Illuminating Oil Company v. State of Oklahoma argued that the majority's decision was inconsistent with previous rulings and interpretations of federal law. The dissenters believed that Congress had not intended to exempt oil produced on restricted Indian lands from state taxation when it passed legislation regulating such lands. They pointed out that similar taxes had been upheld by courts in other states, suggesting a broader acceptance for this interpretation among legal authorities. Furthermore, they contended that allowing such an exemption would unfairly burden non-Indian citizens who were subject to these taxes while benefiting wealthy corporations exploiting natural resources on tribal land. In their view, this could potentially create economic disparities and social tensions within the state.