In the United States v. Moran case of 1922, the Supreme Court ruled on a dispute involving income tax evasion. The defendant, John H. Moran, was charged with willfully attempting to evade and defeat his income tax for the year 1917 by filing a false and fraudulent return. He argued that he had not been properly indicted because there were no allegations in the indictment stating that he owed any additional taxes beyond what he reported in his original return or that any part of it remained unpaid at the time of indictment. The court held against Moran's argument, ruling that an allegation regarding specific amounts due is not necessary for an indictment under section 253 (criminal code). It stated that if someone knowingly understates their taxable income with intent to defraud government revenue, they are guilty whether or not they owe more than what has been paid already. This decision set precedent concerning cases related to tax evasion - proving guilt does not require demonstrating exact amounts owed but rather showing intentional deceitful behavior aimed at evading taxation.

In the dissenting opinion for United States v. Moran, Justice Holmes argued that the defendant's conviction should be upheld. He disagreed with the majority's interpretation of Section 37 of the Penal Code, which made it a crime to conspire to defraud the United States in any manner or for any purpose. The majority held that this section did not apply because there was no intent to cause financial loss to the government; however, Holmes contended that fraud could take many forms and need not necessarily result in monetary damage. He believed that by accepting bribes and conspiring to protect violators of Prohibition laws, Moran had indeed defrauded his employer—the U.S.—of its right to his honest services as an officer enforcing those laws.