The Superintendent of Five Civilized Tribes v. Commissioner of Internal Revenue case in 1934 revolved around the taxation of income derived from restricted Indian lands. The Supreme Court ruled that such income was not exempt from federal income tax, overturning a decision by the Board of Tax Appeals. The court held that Congress had intended for these revenues to be taxed when it passed legislation allowing Indians to lease their allotted lands and receive royalties from oil production on those properties. This ruling clarified that while Native American tribes have sovereignty, they are still subject to certain federal laws including taxation laws.

In the dissenting opinion for Superintendent of Five Civilized Tribes v. Commissioner of Internal Revenue, Justice Stone disagreed with the majority's interpretation that Congress intended to exempt all income derived from restricted Indian lands from federal taxation. He argued that such a broad exemption was not supported by legislative history or previous court decisions and would lead to unjust results. In his view, only income directly derived from land use (such as rent) should be tax-exempt, while other forms of income (like interest on bank deposits) should remain taxable. This distinction is important because it respects tribal sovereignty and self-determination without creating an overly broad tax loophole.