In the case of Inland Steel Co. v. United States et al., 1938, the U.S Supreme Court ruled in favor of the United States government and against Inland Steel Company. The steel company had argued that it should not be required to pay taxes on coal lands leased from a subsidiary corporation because it was essentially paying tax on its own property, thus constituting double taxation. However, the court held that under federal law, a parent company and its subsidiaries are separate entities for tax purposes even if they operate as one economic unit; therefore each entity is subject to taxation independently of each other. This ruling set an important precedent regarding corporate structure and tax liability.

The dissenting opinion in the case of Inland Steel Co. v. United States et al., 1938, argued that the majority's decision to uphold a tax on coal mining companies was incorrect and overstepped constitutional boundaries. The dissenters believed that this tax was not truly an excise tax as defined by the Constitution but rather a direct tax, which would require apportionment among states according to population. They contended that because coal is extracted from land and cannot be manufactured or produced elsewhere, taxing its extraction should be considered a direct taxation on property itself - something only permissible under specific circumstances outlined in the Constitution. Furthermore, they disagreed with the majority's interpretation of previous court decisions related to similar issues and felt these precedents did not support upholding such taxes without apportionment.