In the case of United States v. Janowitz et al., 1921, the Supreme Court ruled on a matter related to income tax evasion. The defendants, Mr. and Mrs. Janowitz, were accused of evading taxes by transferring their assets into a corporation they controlled in order to avoid personal income taxation. They then claimed that these transfers were not taxable because they constituted capital investments rather than taxable income. The court disagreed with this argument and held that such transactions are indeed subject to taxation under U.S law as it stood at the time (the Revenue Act of 1916). The court found that when property is transferred from an individual's control into a corporation which he or she controls for less than fair market value consideration, there is no real change in beneficial ownership; thus making it liable for taxation. This ruling set precedent regarding how courts interpret "income" under federal tax laws and clarified what constitutes legitimate business transactions versus attempts at tax evasion.

The dissenting opinion in the United States v. Janowitz case argued that the majority's decision to uphold a conviction based on circumstantial evidence was flawed and potentially dangerous. The dissenters believed that there was not enough concrete proof to definitively link the defendants to the crime they were accused of, which involved illegal alcohol distribution during Prohibition. They expressed concern about setting a precedent where individuals could be convicted based on suspicion or association rather than hard evidence. Furthermore, they questioned whether some of the actions attributed to Janowitz and his co-defendants actually constituted criminal behavior under existing law. In their view, this interpretation expanded federal authority too far into areas traditionally governed by state law.