In Booth v. United States (1933), the U.S Supreme Court ruled on a case involving tax evasion and fraud. The defendant, Edwin G. Booth, was convicted of evading taxes by underreporting his income for several years and appealed to the Supreme Court arguing that he had been denied due process because the trial judge did not allow him to introduce evidence showing that he had relied on professional advice in preparing his tax returns. He claimed this would have demonstrated good faith and negated any intent to defraud the government. The court rejected this argument stating that reliance on an accountant's advice does not constitute a valid defense against charges of willful attempt to evade or defeat taxation if there is clear proof of fraudulent intent elsewhere in one’s conduct or actions. In other words, even if someone else prepares your taxes, you are still legally responsible for all information reported. This ruling established precedent regarding taxpayer responsibility and clarified what constitutes as willful evasion of federal income tax laws.

In the dissenting opinion for Booth v. United States, it was argued that the majority's decision to uphold Booth's conviction based on evidence obtained through wiretapping violated his Fourth Amendment rights against unreasonable searches and seizures. The dissenting justices contended that wiretapping constituted a form of search and seizure, even if it did not involve physical intrusion into private property. They believed that allowing such practices would undermine citizens' privacy rights and set a dangerous precedent for future cases involving technological surveillance methods. Furthermore, they disagreed with the majority's assertion that conversations could be seized in the same way as tangible objects or documents under existing law enforcement procedures. In their view, this interpretation stretched the meaning of "seizure" beyond its original intent in order to justify an invasive investigative technique.