In the United States v. Alford case of 1926, the Supreme Court ruled on a matter concerning federal income tax law. The defendant, Alford, had been assessed additional taxes and penalties by the Commissioner of Internal Revenue for allegedly underreporting his income in 1917 and 1918. In response to this assessment, Alford filed a lawsuit against the government seeking recovery of these funds. However, he failed to provide evidence supporting his claim that he did not owe any additional taxes beyond what he initially reported. The Supreme Court held that it was incumbent upon Alford as plaintiff to prove that the Commissioner's determination was incorrect or excessive if he wished to recover any part of what was paid under protest following such an assessment. It further stated that without such proof from him showing error in computation or illegality in principle adopted by commissioner who made it - there could be no recovery at all. Therefore, because Mr. Alford failed to meet this burden of proof regarding his alleged overpayment due to errors in calculation or principles applied by commissioner making original decision - judgment went against him.

In the dissenting opinion for United States v. Alford, Justice Holmes argued that the defendant's conviction should be overturned because it was based on evidence obtained through an illegal search and seizure. He contended that the Fourth Amendment protects citizens from unreasonable searches and seizures, which includes those conducted by federal officers without a warrant or probable cause. In this case, he believed that there was no justification for such a violation of privacy rights as there were other legal means available to obtain evidence against Alford. Furthermore, he expressed concern about setting a precedent where constitutional protections could be disregarded in pursuit of criminal convictions. This view did not prevail in court; however, it laid groundwork for future decisions upholding Fourth Amendment protections.