In the case of Campbell et al. v. United States, 1960, the Supreme Court ruled on a matter concerning federal income tax law and its application to payments made by an employer into a trust fund for employee benefits. The question was whether these contributions should be considered taxable income for the employees at the time they were made or only when actually received by them as benefits from the trust fund. The court held that such contributions are not taxable income until they are paid out to beneficiaries in accordance with their vested rights under terms of trust agreement. This decision clarified how deferred compensation plans like pensions and retirement funds would be treated under U.S tax law, ruling that money placed in such funds is not considered part of an employee's gross income until it is distributed.

In the dissenting opinion for Campbell et al. v. United States, Justice Frankfurter argued that the majority's decision to reverse and remand the case was incorrect as it failed to properly consider precedent set by previous cases regarding tax evasion charges. He contended that there was sufficient evidence presented at trial proving beyond a reasonable doubt that defendants had willfully attempted to evade taxes, which is a criminal offense under federal law. Furthermore, he disagreed with the majority's interpretation of Spies v. United States (1943), arguing instead that this case established clear guidelines for what constitutes an attempt to evade or defeat tax payment - namely any conduct constituting "the commission of affirmative acts". In his view, these actions were clearly demonstrated in this case through false statements made on income tax returns filed by defendants over several years.