In the United States v. Julian case of 1895, the Supreme Court dealt with a dispute over land ownership in California. The defendant, Julian, claimed that he had purchased his property from individuals who held valid Mexican land grants predating American sovereignty over California. However, these claims were never presented to or confirmed by the Board of Land Commissioners as required under an act passed by Congress in 1851 for all pre-existing Mexican land grants. The U.S government argued that it was therefore entitled to possession of this unconfirmed grant and initiated legal proceedings against Julian. The Supreme Court ruled in favor of the U.S government stating that any claimant holding a title based on a Mexican grant must present their claim before the board within two years after passing of said act; failure to do so would render their titles null and void against any adverse party claiming under United States authority. Thus, since Julian's predecessors failed to confirm their title within stipulated time period they lost rights over disputed lands which then belonged rightfully to US Government.

In the dissenting opinion for United States v. Julian, the justice argued that the majority's ruling was inconsistent with previous interpretations of tax law and could potentially lead to unjust outcomes in future cases. The dissenting judge disagreed with the majority's interpretation of "gross income," arguing that it should not include money received from illegal activities since such funds are not typically considered a source of wealth or profit under tax law. Furthermore, he contended that including illegally obtained funds as taxable income would essentially legitimize criminal activity by treating it as a legitimate form of business enterprise subject to taxation. He also expressed concern about potential double punishment issues, where individuals could be penalized both criminally for their illegal actions and financially through taxation on those same illicit gains.