United States v. Gaussen was a United States Supreme Court case that dealt with the issue of whether a federal court had the power to issue a writ of habeas corpus to a state court. The case involved a man named Gaussen, who had been convicted of murder in a state court in California. Gaussen had appealed his conviction to the California Supreme Court, but the court had denied his appeal. Gaussen then filed a petition for a writ of habeas corpus in the United States District Court for the Northern District of California. The district court granted the writ, and Gaussen was released from custody. The United States government appealed the district court's decision to the Supreme Court, arguing that the district court had no authority to issue the writ of habeas corpus. The Supreme Court agreed with the government, holding that the district court did not have the power to issue the writ. The Court reasoned that the writ of habeas corpus was a remedy that was available only in federal courts, and that the district court had no authority to interfere with the state court's decision. As a result, the Supreme Court reversed the district court's decision and Gaussen was returned to custody.

Justice Field delivered the dissenting opinion in United States v. Gaussen, arguing that the majority's decision was incorrect and should be reversed. He argued that Congress had not intended to impose a tax on income from real estate transactions when it passed the Revenue Act of 1862, which imposed an income tax for individuals and corporations. Instead, he argued that Congress only intended to levy taxes on incomes derived from business activities or professions such as those of merchants, manufacturers, bankers and brokers. Furthermore, Justice Field noted that if Congress had wanted to include real estate transactions in its definition of taxable "income," it would have done so explicitly rather than leaving this interpretation open to debate by courts. In conclusion, Justice Field maintained his belief that no taxation should be applied unless specifically authorized by law; thus he concluded with a dissent against the majority opinion upholding taxation on income derived from real estate transactions without explicit authorization by statute.