In the United States v. Miller case of 1984, the Supreme Court ruled on a matter concerning tax evasion and fraud. The defendant, Miller, was convicted for willfully attempting to evade his income taxes by underreporting his earnings from illegal gambling operations in violation of federal law (26 U.S.C §7201). He appealed this conviction arguing that he should not be prosecuted because reporting such income would incriminate him in violation of the Fifth Amendment's protection against self-incrimination. However, the Supreme Court rejected this argument stating that there is no constitutional right to avoid paying taxes on illegally earned income. They further clarified that while individuals cannot be compelled to disclose information which may incriminate them directly, they are still required by law to report their total annual income regardless of its source or legality.

In the dissenting opinion for United States v. Miller, Justice Brennan argued that the majority's decision to allow warrantless inspection of commercial premises under a federal statute was an erosion of Fourth Amendment protections against unreasonable searches and seizures. He contended that such inspections should require either consent or a warrant based on probable cause, as with residential properties. The justice also expressed concern about potential abuse by law enforcement officials who might use this power arbitrarily or discriminatorily without judicial oversight. Furthermore, he disagreed with the majority's view that businesses have lower expectations of privacy than homes due to regulations; instead asserting all property owners should enjoy equal protection from unwarranted intrusions by government authorities regardless of whether their premises are used for business or residence purposes.