In the case of Westfall v. United States in 1926, the U.S Supreme Court ruled on a matter concerning federal income tax law. The plaintiff, Westfall, was an investor who had purchased land with oil reserves and leased it to an oil company for extraction purposes. He claimed that he should be entitled to deductions from his gross income based on depletion allowances - a provision allowing taxpayers involved in natural resource extraction to account for reduction in resources' quantity over time. However, the government argued that since Westfall did not operate or manage any part of the drilling operations himself but merely received royalties from leasing out his property rights, he could not claim these deductions. The Supreme Court sided with the government's argument stating that only those directly involved in mining or other forms of resource extraction were eligible for such tax benefits under existing laws at that time. Therefore, as per this ruling by Justice Butler and others present during this case hearing session; mere ownership and leasing out one's property rights do not qualify someone as being 'engaged' enough within industry operations so they can avail themselves of certain taxation advantages like depletion allowances.

The dissenting opinion in the case of Westfall v. United States argued that the majority's decision was flawed because it failed to properly interpret and apply relevant statutory law. The dissenters believed that the statute at issue did not intend for a person to be convicted based on mere possession of liquor, but rather required proof of intent to sell or distribute illicit alcohol. They contended that by convicting Westfall merely for possessing alcohol, without any evidence he intended to sell or distribute it illegally, the court had effectively rewritten the statute and overstepped its judicial authority. Furthermore, they expressed concern about potential abuses of power and violations of individual rights if such an expansive interpretation were allowed to stand.