In Bray v. United States (1975), the Supreme Court ruled on a case involving income tax evasion. The defendant, Bray, was convicted of willfully attempting to evade his 1961 and 1962 federal income taxes by filing false returns that understated his taxable income for those years. He appealed the conviction arguing that there was insufficient evidence to prove he acted "willfully" in evading taxes as required under law. However, the Supreme Court upheld Bray's conviction stating that sufficient circumstantial evidence existed demonstrating willfulness in his actions including maintaining two sets of books and records for business purposes; one set accurately reflecting gross receipts while another showed less than actual amounts received which were used for preparing tax returns. Furthermore, it noted that intent can be inferred from conduct meant to conceal or mislead.

In the dissenting opinion for Bray v. United States, it was argued that the majority's decision to uphold a conviction based on an individual's failure to report all of their income from illegal activities is flawed. The dissenting justices believed that this interpretation of tax law could potentially infrive upon Fifth Amendment protections against self-incrimination. They contended that requiring individuals to report illegal income would essentially force them into admitting criminal activity, which goes against constitutional rights. Furthermore, they expressed concern about how such reporting requirements might be enforced and whether they could lead to potential abuses of power by government authorities seeking information about illicit activities under the guise of tax collection efforts.