In the case of Snow et ux. v. Commissioner of Internal Revenue (1973), the U.S Supreme Court dealt with a tax dispute involving a married couple, Mr. and Mrs. Snow, who had received income from selling their home in Massachusetts to move to Florida for health reasons. The issue was whether this income could be considered "sick pay" under section 105(d) of the Internal Revenue Code and thus exempted from federal income tax because they moved due to medical advice that warmer climate would benefit Mr.Snow's health condition. The court ruled against them stating that proceeds from sale of property cannot be treated as compensation for personal injuries or sickness under Section 105(d). Therefore, it is not excluded from gross income and should be taxed accordingly.

In the dissenting opinion for Snow et ux. v. Commissioner of Internal Revenue, Justice Douglas argued that the majority's decision was inconsistent with previous rulings and unfairly penalized taxpayers who were not in a position to know or understand complex tax laws. He contended that it was unreasonable to expect ordinary citizens to be aware of obscure provisions in tax law, especially when those provisions had been interpreted differently by different courts. Furthermore, he believed that the court should have taken into account whether or not the taxpayer acted in good faith and made reasonable efforts to comply with their obligations under tax law before imposing penalties for non-compliance.