In the case of Pine Hill Coal Company, Inc. v. United States (1921), the Supreme Court ruled in favor of the U.S government regarding a dispute over coal land leases in Alaska. The Pine Hill Coal Company had argued that they were entitled to certain rights and privileges under their lease agreement with the federal government, which included exclusive possession and enjoyment of leased lands for mining purposes. However, upon review, it was found that these claims were not supported by any specific provisions within their contract or existing legislation at that time. Therefore, the court held that while lessees are granted some rights for mining operations on leased lands under Alaskan coal leasing laws; this does not extend to absolute control or ownership over those properties beyond what is explicitly stated in their agreements or prescribed by law.

The dissenting opinion in the case of Pine Hill Coal Company, Inc. v. United States argued that the majority's decision to uphold a federal tax on coal mined and sold by the company was unconstitutional. The dissenters believed that this tax violated principles of federalism because it intruded upon state powers to regulate their own natural resources. They also contended that such a tax constituted an improper direct levy without apportionment among states as required by Article I, Section 9 of the Constitution for non-income taxes. Furthermore, they disagreed with the majority's interpretation of "income" under Sixteenth Amendment which allowed Congress to impose income taxes without apportionment; they asserted that proceeds from sale of coal were not "income" but rather part and parcel of capital assets themselves being depleted through mining operations - thus should be exempted from taxation.