In the United States v. Henning et al., 1952, the Supreme Court dealt with a case concerning federal income tax evasion. The defendants, Mr. and Mrs. Henning, were accused of evading taxes by not reporting their full income from their business operations in 1946 and 1947. They argued that they had relied on an accountant to prepare their returns and therefore lacked willful intent to defraud the government - a necessary element for conviction under applicable law at that time. The court ruled against them stating that reliance on an accountant or any other expert does not absolve taxpayers of responsibility for ensuring accurate information is reported on tax returns; ignorance or misunderstanding of law doesn't constitute as defense against charges of willful violation unless there's evidence proving good faith misunderstanding about legal duties regarding taxation. This ruling established precedent emphasizing taxpayer’s ultimate responsibility for accuracy in filing taxes regardless if services are outsourced to professionals like accountants.

The dissenting opinion in the case of United States v. Henning et al., 1952, argued that the majority's interpretation of Section 22(a) of the Internal Revenue Code was incorrect and overly broad. The dissenting justices believed that this section should not apply to cases where a taxpayer has received income from selling property for more than its cost but less than its fair market value at the time it was acquired by gift or inheritance. They contended that such an interpretation would result in unfair taxation and could lead to absurd results if applied consistently across all similar situations. Furthermore, they disagreed with the majority's view on how "income" should be defined under federal tax law, arguing instead for a narrower definition based on realized gain rather than potential gain.