The Morrisdale Coal Company v. United States case in 1921 revolved around the interpretation of a federal tax law related to coal mining operations. The Morrisdale Coal Company challenged the government's assessment of taxes on its mined coal, arguing that it was exempt from such taxation under an Act passed by Congress in 1918 which provided for deductions from gross income for depletion of mines based on their production. However, the Supreme Court ruled against Morrisdale Coal Company and upheld the tax assessments made by the U.S government. The court found that while there were provisions allowing certain deductions for mineral resources extraction, these did not apply to all forms of mining or all minerals extracted; rather they applied only where specifically stated within legislation. In this case, no specific provision existed covering coal extraction so no deduction could be claimed.

In the dissenting opinion for Morrisdale Coal Company v. United States, it was argued that the government did not have a valid claim to royalties from coal mined on leased land after the expiration of its lease. The dissenting justices believed that once the lease expired, all rights reverted back to the lessee and any subsequent mining operations were outside of governmental jurisdiction. They contended that under common law principles, an owner is entitled to minerals extracted from their property unless explicitly stated otherwise in a contract or agreement. In this case, they found no such explicit provision in favor of the government within Morrisdale's original leasing contract with them; therefore, they concluded that post-expiration royalties should rightfully belong to Morrisdale Coal Company rather than being claimed by U.S Government as per majority ruling.