In the United States v. Kaplan case of 1937, the Supreme Court ruled on a matter involving bankruptcy and tax law. The respondent, Kaplan, had filed for bankruptcy in 1929 and his assets were placed under control of a trustee. In 1931, while still bankrupt but before final settlement with creditors was reached, he received income from various sources which he did not report to the Internal Revenue Service (IRS). The IRS sought to collect taxes on this income by filing claims against his estate in bankruptcy court. However, Kaplan argued that since these earnings came after his declaration of bankruptcy they should be exempt from taxation as post-bankruptcy earnings are typically considered separate from pre-bankruptcy debt obligations. The Supreme Court disagreed with Kaplan's argument and sided with the IRS stating that until discharge is granted or denial has become final after an adjudication or it has been waived by all parties in interest; property acquired by a bankrupt is subject to administration for benefit of creditors including taxing authorities.

The dissenting opinion in the United States v. Kaplan case argued that the majority's decision to uphold a conviction for conspiracy to defraud the government through mail fraud was incorrect. The dissenters believed that there was insufficient evidence presented at trial to prove beyond a reasonable doubt that Kaplan knowingly and willingly participated in a scheme designed to deceive and cheat the government out of money or property, which is required under federal law for such convictions. They contended that mere association with those involved in fraudulent activities does not necessarily equate guilt, especially without clear proof of intent or knowledge of wrongdoing on his part. Therefore, they felt it was unjustified and unfair to hold him criminally liable based solely on circumstantial evidence and speculation about his involvement in these illegal acts.