In Rosenbloom v. United States, the Supreme Court was asked to consider whether a federal tax statute that imposed different rates on "recognized gains" from the sale of property applied to an individual who had acquired his assets through inheritance and then sold them. The petitioner, David Rosenbloom, argued that he should not be subject to higher taxes because he did not acquire his assets in a traditional business transaction but rather inherited them after death of his father. However, the court ruled against him stating that there is no distinction between properties acquired by purchase or inheritance under this particular law (Section 117(j) of Internal Revenue Code). Therefore, Rosenbloom was liable for paying taxes at regular rates on gains from sales of such properties regardless how they were originally obtained.

In the dissenting opinion for Rosenbloom v. United States, it was argued that the majority's decision to uphold a conviction based on circumstantial evidence was flawed. The dissenting justices believed that there were reasonable doubts about the defendant's guilt and therefore he should not have been convicted. They pointed out inconsistencies in witness testimonies and questioned whether these could be relied upon as solid evidence of guilt. Furthermore, they criticized the prosecution’s reliance on assumptions rather than concrete proof to build their case against Rosenbloom. In conclusion, they contended that due process had not been served because of these issues with how evidence was handled during trial proceedings.