In the case of Michaels Enterprises, Inc. et al. v. United States in 1963, the Supreme Court ruled on a matter concerning federal income tax law and its application to corporate dividends paid by an insurance company subsidiary to its parent corporation. The court held that such dividends were not deductible as "dividends received" under Section 243(a) of the Internal Revenue Code because they did not meet certain requirements for deductibility outlined in Section 243(c). Specifically, these requirements stipulate that only those dividends which are paid out of earnings and profits accumulated after February 28th, 1913 can be deducted from taxable income; any other types of dividend payments do not qualify for this deduction. The petitioner was Michaels Enterprises - a holding company owning several subsidiaries including an insurance firm named National Casualty Company (NCC). NCC had declared substantial dividends payable to Michaels during two fiscal years but had no earnings or profits during those periods due to losses incurred from operations and investments. Michaels argued that it should still be allowed deductions based on these dividend payments despite them being sourced from capital rather than post-1913 earnings/profits since there was no explicit prohibition against such treatment within existing tax laws/regulations at the time. However, both lower courts and ultimately SCOTUS disagreed with this interpretation upholding IRS's denial of claimed deductions thereby affirming prior rulings.

In the dissenting opinion for Michaels Enterprises, Inc. v. United States (1963), Justice Harlan argued that the majority's interpretation of Section 605 of the Federal Communications Act was too broad and inconsistent with its legislative history. He contended that Congress intended to protect only those communications which were meant to be confidential or private in nature, not all communications transmitted over wire or radio as interpreted by the majority. Furthermore, he disagreed with their view that a party involved in a communication could not consent to its interception without violating Section 605; instead, he believed such an individual had every right to do so if they wished. Lastly, Justice Harlan expressed concern about potential abuses stemming from this ruling - namely law enforcement agencies using third parties' consents as loopholes around obtaining necessary warrants for surveillance activities.