In the case of United States v. A. Graf Distilling Company, the U.S. Supreme Court ruled in favor of the government and against A. Graf Distilling Company, a whiskey distiller accused of tax evasion by underreporting its production volume to avoid paying full taxes on it. The company argued that they were not liable for these taxes because they had lost some quantity of their product due to evaporation during storage (known as "the angel's share"). However, the court rejected this argument stating that such losses are normal in business operations and should be accounted for when reporting production volumes for taxation purposes. Therefore, any loss due to evaporation does not exempt them from paying full taxes on all produced goods before such loss occurred.

In the dissenting opinion for United States v. A. Graf Distilling Company, it was argued that the majority's interpretation of the law was too broad and could potentially lead to unjust outcomes in future cases. The dissenting justices believed that a more narrow reading of the statute would be more appropriate, as this would better align with its original intent and purpose. They also expressed concern about potential overreach by federal authorities if such a wide interpretation were allowed to stand unchallenged. Furthermore, they disagreed with how evidence had been handled during trial proceedings and felt that certain pieces should not have been admitted due to their questionable relevance or reliability.