In the case of G. M. Leasing Corp. et al v United States et al., 1976, the U.S Supreme Court ruled that Fourth Amendment protections against unreasonable searches and seizures apply to civil as well as criminal investigations conducted by federal authorities, but do not always require a warrant or prior notice before seizure of property for tax collection purposes. The court held that IRS agents violated George Pflaum's constitutional rights when they entered his home without a warrant to seize assets in order to satisfy his alleged $400,000 tax debt; however, it also upheld other seizures made from Mr. Pflaum’s office and bank because these did not involve physical intrusion into any constitutionally protected area.

In the dissenting opinion for G. M. Leasing Corp. et al v United States et al., Justice Marshall argued that the majority's decision to allow warrantless seizures of property by IRS agents was a dangerous expansion of government power and an erosion of Fourth Amendment protections against unreasonable searches and seizures. He contended that such actions should require a warrant, obtained after demonstrating probable cause before a neutral magistrate, as is required in other circumstances involving seizure or search of private property by law enforcement officials. The justice expressed concern about potential abuse if this precedent were applied broadly beyond tax collection situations, arguing it could lead to unchecked governmental intrusion into citizens' privacy rights without proper judicial oversight.