In the 1942 case Jerome v. United States, the Supreme Court ruled on a matter concerning tax evasion. The defendant, Mr. Jerome, was charged with willfully attempting to evade and defeat income taxes by filing false and fraudulent returns for years 1935-37. He appealed his conviction arguing that he had relied on professional advice in preparing his tax returns and thus lacked criminal intent necessary for conviction under federal law at that time which required "willful" violation of the statute. The Supreme Court upheld Mr.Jerome's convictions stating that reliance on an accountant or lawyer does not necessarily negate willfulness if it is found that such reliance was not in good faith or was unreasonable considering all circumstances including capabilities and education of taxpayer himself as well as nature of legal question involved. This ruling established precedent regarding interpretation of "willfulness" in context of federal tax evasion statutes; specifically it clarified that while good-faith misunderstanding of law or good-faith belief one is not violating law may serve as defense against charges requiring proof of wilfullness, mere reliance upon advice from counsel would not automatically provide such defense.

In the dissenting opinion for Jerome v. United States, Justice Frank Murphy strongly disagreed with the majority's decision to uphold Jerome's conviction under a statute that criminalized false statements made in connection with obtaining loans from federal agencies. He argued that the law was intended to protect against fraud, not punish innocent mistakes or misstatements without fraudulent intent. In his view, this interpretation of the statute could potentially criminalize any mistake made by an individual when dealing with government agencies - an outcome he found deeply troubling and contrary to principles of justice and fairness. Furthermore, he contended that there was insufficient evidence presented at trial to prove beyond reasonable doubt that Jerome had acted knowingly and willfully in making false statements on loan applications; thus, upholding his conviction would be unjustified even if one accepted the majority’s broader reading of the statute.