In the Greene v. United States case of 1963, the Supreme Court ruled on a matter involving tax evasion and fraud. The defendant, Mr. Greene, was charged with attempting to evade or defeat taxes by filing fraudulent income tax returns for two years consecutively. He argued that he could not be prosecuted because his Fifth Amendment rights were violated when he was compelled to provide incriminating evidence against himself in an earlier civil audit by the Internal Revenue Service (IRS). However, the Supreme Court disagreed with this argument stating that there had been no compulsion as defined under constitutional law during his IRS interview since it was voluntary and not forced upon him through legal means such as subpoena or court order. Therefore, any self-incriminating statements made during this time were admissible in court proceedings against him for tax evasion charges.

In the dissenting opinion for Greene 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 only be invoked in exceptional circumstances where an error not raised at trial seriously affects substantial rights or results in a miscarriage of justice. According to him, there were no such exceptional circumstances present in this case as Greene had ample opportunity during his trial to challenge the admissibility of certain evidence but failed to do so until after his conviction. Therefore, he believed it was inappropriate for the Supreme Court to intervene post-trial when procedural rules were not followed properly by defense counsel during trial proceedings.