In the United States v. Hughes Properties, Inc., 1985, the Supreme Court ruled in favor of Hughes Properties. The case revolved around whether or not a casino had to pay taxes on unclaimed progressive slot machine jackpots. The Internal Revenue Service (IRS) argued that these should be taxable as they were potential income for the company. However, Hughes Properties contended that since it was unknown when and if these jackpots would be won, they could not be considered part of their gross income and therefore should not be taxed. The Supreme Court agreed with Hughes' argument stating that under Section 61(a) of the Internal Revenue Code which defines gross income as "all income from whatever source derived," does not include contingent events such as winning a jackpot at an undetermined future date because there is no claim to access those funds until someone wins them.

In the dissenting opinion for United States v. Hughes Properties, Inc., Justice White disagreed with the majority's interpretation of tax law regarding reserve funds for progressive slot machines. He argued that a company should only be able to deduct from its taxes an amount equal to what it is contractually obligated to pay out, not potential future payouts. The majority had ruled that Hughes Properties could deduct all money put into a reserve fund for a progressive jackpot because they would eventually have to pay it out when someone won the jackpot. However, Justice White pointed out there was no guarantee this would happen within any specific timeframe or even at all if the machine broke or was retired before being hit by anyone winning combination; thus he believed allowing such deductions did not accurately reflect income and violated principles of annual accounting.