In the case of Bingler v. Johnson et al., 1968, the U.S Supreme Court was tasked with determining whether payments made to individuals participating in a clinical study could be considered as "gross income" under section 61(a) of the Internal Revenue Code and thus subject to federal income tax. The respondents, who were part of a group that received such payments from pharmaceutical companies for their participation in drug testing trials, argued that these amounts did not constitute taxable gross income but rather gifts or windfalls. However, the court ruled against them stating that these payments fell within the broad definition of gross income provided by Congress which includes all gains derived from any source unless explicitly exempted by law. Therefore, they are indeed taxable under federal law.

In the dissenting opinion for Bingler v. Johnson, Justice Harlan argued that the majority's interpretation of "dependent" in Section 152(a) of the Internal Revenue Code was too broad and inconsistent with Congressional intent. He believed that Congress intended to limit dependency exemptions to those who provide over half of an individual’s support, not merely individuals who contribute a significant amount towards their own support as interpreted by the majority. Furthermore, he contended that this broader definition could lead to potential abuses where multiple taxpayers claim deductions for supporting one person or where a taxpayer claims a deduction without actually providing substantial financial assistance. Therefore, he disagreed with allowing taxpayers to deduct expenses related to foster children under certain circumstances.