The U.S. Supreme Court case W.P. Brown & Sons Lumber Company v. Burnet, Commissioner of Internal Revenue in 1930 revolved around the issue of income tax liability for a corporation that had dissolved but continued to operate as a partnership under the same name. The court ruled against W.P. Brown & Sons Lumber Company, stating that it was liable for paying taxes on its income earned after dissolution because it continued to conduct business operations and generate profits even though its corporate status had ended officially. In essence, this ruling established that if an entity continues to function and earn income post-dissolution without any significant changes in operation or ownership structure, then it is still subject to taxation as per existing laws regardless of whether it has formally ceased being a corporation or not.

In the dissenting opinion for W. P. Brown & Sons Lumber Company v. Burnet, it was argued that the majority's decision to tax a corporation on its undistributed earnings was inconsistent with previous rulings and interpretations of tax law. The dissenters believed that this ruling would unfairly burden corporations by taxing them twice: once when they earned their income, and again when they distributed it as dividends to shareholders. They also pointed out that other types of businesses, such as partnerships or sole proprietorships, were not subject to this double taxation under similar circumstances. Furthermore, they disagreed with the majority's interpretation of "income," arguing that undistributed corporate profits should not be considered taxable income until actually realized through distribution or sale.