In the case of Holland et ux. v. United States, 1954, the Supreme Court ruled that in tax evasion cases, it is not necessary for the government to prove a specific item from which unreported income was derived. The Hollands were charged with willfully attempting to evade and defeat their income taxes by filing fraudulent returns for three years. They argued that they had no obligation to report any net income unless the Government could show its source or nature; however, this argument was rejected by both lower courts and eventually by the Supreme Court as well. The court held that circumstantial evidence can be used in such cases and direct proof of a likely source isn't required if there's substantial evidence indicating guilt when viewed in conjunction with other information presented at trial. Furthermore, it clarified that "net worth" method (calculating an individual’s annual increase in assets) can be employed as long as certain safeguards are met: ensuring starting point accuracy; investigating leads furnished by taxpayers about possible sources of non-taxable income; proving closing net worth accurately etc., thereby setting important precedents regarding tax evasion prosecutions.

In the dissenting opinion for Holland et ux. v. United States, Justice Robert H. Jackson disagreed with the majority's decision to uphold a conviction based on net worth calculations in tax evasion cases without requiring specific evidence of taxable income or willful evasion. He argued that this method was unreliable and could lead to wrongful convictions due to its reliance on assumptions and estimates rather than concrete proof of wrongdoing. Furthermore, he contended that it violated constitutional protections against vague laws by allowing prosecutors too much discretion in determining what constitutes tax evasion under these circumstances. He also expressed concern about potential abuses of power by government officials using this method as a tool for political persecution or personal vendettas.