In the case of Campbell et al. v. United States, 1962, the Supreme Court ruled on a matter involving federal income tax law and its application to certain types of property transactions. The petitioners were partners in a real estate business who had exchanged properties with another party under Section 112(b)(1) of the Internal Revenue Code, which allowed for non-recognition of gain or loss from such exchanges if they were "like-kind". However, after an audit by the IRS revealed that one parcel involved in this exchange was subject to a mortgage significantly larger than its fair market value at time of exchange (creating potential taxable boot), it resulted in additional taxes being assessed against them. The petitioners challenged these assessments arguing that their liability should be limited only to their equity interest rather than full value including debt assumed by other party. The Supreme Court disagreed with petitioners' interpretation and upheld lower court's decision favoring IRS stating that when determining amount realized from disposition of property through like-kind exchanges under section 112(b)(1), any liabilities assumed by other party as part of transaction must also be included along with cash received or fair market value.

In the dissenting opinion for Campbell et al. v. United States, Justice Harlan argued that the majority's decision to reverse and remand the case was based on a misinterpretation of Rule 52(b) of Federal Rules of Criminal Procedure. He contended that this rule should not be used as a vehicle to correct errors which were not brought up at trial unless they seriously affect substantial rights or result in miscarriages of justice. In his view, there was no such error in this case because it did not involve constitutional issues nor did it have an unfair impact on the defendants' opportunity for a fair trial. Furthermore, he believed that even if there had been an error regarding jury instructions about entrapment defense, it would have been harmless beyond reasonable doubt given other overwhelming evidence against defendants including their own admissions and testimonies from numerous witnesses.