In Haynes et ux. v. United States (1956), the Supreme Court ruled on a case involving the prosecution of individuals for tax evasion under Section 145(b) of the Internal Revenue Code, which criminalizes willful attempts to evade or defeat any tax imposed by federal law. The defendants, Mr. and Mrs. Haynes, were charged with evading income taxes in 1946 by filing fraudulent joint returns that understated their taxable income and overstated their deductions. The main issue before the court was whether it was necessary for the government to prove that there had been an actual tax deficiency in order to secure a conviction under Section 145(b). In other words, could someone be convicted of attempting to evade taxes even if they did not actually owe any additional taxes? The Supreme Court held that proof of an actual tax deficiency is indeed required for a conviction under Section 145(b). Therefore, because no such evidence had been presented at trial against Mr. and Mrs.Haynes , their convictions were overturned.

In the dissenting opinion for Haynes v. United States, it was argued that the majority's decision failed to adequately protect Fifth Amendment rights against self-incrimination. The dissenting justices believed that requiring individuals to register firearms effectively forced them into a situation where they had to incriminate themselves or face criminal charges for failing to comply with registration laws. They contended this was a clear violation of constitutional protections and expressed concern about the potential implications of such an interpretation on other areas of law enforcement and regulation. Furthermore, they disagreed with the majority's assertion that there were sufficient safeguards in place within existing legislation to prevent misuse of self-incriminating information obtained through firearm registrations.