In Schreiner v. United States (1971), the Supreme Court ruled on a case involving a taxpayer who had sold his ranch and then leased it back from the buyer, claiming that he was entitled to capital gains treatment for the sale proceeds. The IRS disagreed, arguing that this arrangement constituted an installment sale followed by a leaseback, which should be treated as ordinary income rather than capital gain. The court sided with the IRS in its decision. The key issue in this case was whether or not Schreiner's transaction could be considered a "sale or exchange" under section 1231 of the Internal Revenue Code - which would qualify him for preferential tax treatment - or if it was merely an installment sale and subsequent leaseback. In their ruling, they determined that despite appearing like two separate transactions on paper (a sale and then a lease), these actions were so closely related in substance that they should be viewed as one single transaction for tax purposes. This meant treating them as part of an overall plan designed to allow Schreiner to continue using his property while also benefiting from favorable tax rates associated with selling assets at profit – something Congress did not intend when drafting Section 1231.

In the dissenting opinion for Schreiner v. United States, it was argued that the majority's decision to uphold Schreiner's conviction under 18 U.S.C. § 2113(a) and (d) was incorrect because there wasn't sufficient evidence to prove that he had committed an act of violence or intimidation during a bank robbery. The dissenting justices believed that while Schreiner may have been guilty of theft, his actions did not meet the specific criteria required for a conviction under this statute - namely, assault with dangerous weapons or putting lives in jeopardy by using such weapons during a robbery. They contended that merely being armed does not equate to committing an act of violence or intimidation if no explicit threat is made or action taken with said weapon; therefore, they felt his sentence should be reduced accordingly.