In the 1982 case Regan, Secretary of Treasury, et al. v. Taxation with Representation of Washington (TWR), the U.S Supreme Court ruled that Congress can constitutionally limit tax deductions for lobbying expenses to veterans' organizations without violating First Amendment rights. TWR, a non-profit organization dedicated to promoting public interest in federal taxation issues, challenged a provision in the Internal Revenue Code which denied them tax-deductible contributions because they engaged in substantial lobbying activities. The court held that there was no violation as Congress did not inhibit TWR from exercising its freedom of speech or prevent it from lobbying; rather it simply chose not to subsidize such activities through providing tax benefits.

In the dissenting opinion of Regan v. Taxation with Representation of Washington, Justice Blackmun argued that the majority's decision was a violation of First Amendment rights. He contended that by denying tax-exempt status to organizations engaged in substantial lobbying activities, it effectively limited their ability to express political views and influence legislation. Furthermore, he disagreed with the majority's assertion that Congress had not infringed upon these groups' freedom of speech because they could still create separate entities for lobbying purposes; instead, he believed this created unnecessary financial burdens and administrative complexities. Finally, Blackmun expressed concern over potential governmental manipulation or bias in determining what constituted "substantial" lobbying activity.