In the case of United States v. Noveck, the Supreme Court ruled on a matter concerning perjury and its implications in relation to tax returns. The defendant, Noveck, had been convicted for committing perjury by knowingly underreporting his income on his federal tax return. On appeal, he argued that since the law required him to file a return or face penalties for not doing so - it was essentially compelling him to be a witness against himself which is prohibited by Fifth Amendment rights against self-incrimination. However, the Supreme Court disagreed with this argument stating that there was no compulsion involved as he could have chosen not to file at all or filed without making false statements; hence it did not violate any constitutional right against self-incrimination. Therefore, they upheld Noveck's conviction.

In the dissenting opinion for United States v. Noveck, Justice Oliver Wendell Holmes Jr. argued that a person cannot be convicted of perjury if they believe their false statement to be irrelevant to the case at hand. He reasoned that perjury requires not only making a false statement but also understanding its potential impact on the outcome of proceedings. In this particular case, Noveck had lied about his prior criminal record during bankruptcy proceedings because he believed it was unrelated and would prejudice him unfairly in court. According to Holmes, since Noveck did not understand how his lie could affect the bankruptcy decision, he should not have been found guilty of perjury.