In the United States v. Boyd case of 1963, the Supreme Court ruled on a tax dispute involving an oil company's claim for depletion allowance deductions. The Commissioner of Internal Revenue had denied these claims, arguing that they were not permissible under Section 613 of the Internal Revenue Code because it only allowed such deductions for taxpayers who held economic interests in oil deposits and bore financial risks associated with extraction. However, Boyd argued that his contracts with landowners gave him exclusive rights to extract and sell oil from their properties and thus constituted an economic interest eligible for depletion allowances. The Supreme Court sided with Boyd, ruling that he did indeed have an "economic interest" in the extracted minerals as defined by applicable tax laws at the time. Therefore, he was entitled to claim depletion allowances on his income taxes despite not owning or leasing any mineral lands himself but merely having contractual agreements allowing him to extract and sell minerals from others' properties.

In the dissenting opinion for United States et al. v. Boyd, Commissioner, 1963, Justice Harlan argued that the majority's decision to allow a taxpayer to deduct from his gross income any amount paid as interest on indebtedness incurred or continued in purchasing or carrying obligations of the United States was incorrect. He believed this interpretation of Section 265(2) of the Internal Revenue Code was not consistent with its legislative history and purpose. According to him, Congress intended this provision to prevent taxpayers from creating artificial losses through borrowing money at high-interest rates and then investing it in low-yield government securities which would generate tax-free interest income while allowing them to claim deductions for their loan interests against other taxable incomes. Therefore, he felt that such deduction should only be disallowed when there is an arbitrage motive behind these transactions rather than being applied universally regardless of intent or circumstances as per majority’s ruling.