In the case of United States v. Patrick et al., 1962, the Supreme Court dealt with issues related to tax evasion and fraud. The defendants, including a lawyer named Patrick, were accused of creating fictitious entities in order to evade taxes on income from illegal gambling operations. They were charged under Section 7201 and Section 371 of Internal Revenue Code for willfully attempting to evade or defeat tax and conspiracy respectively. However, they argued that their actions did not constitute an attempt at evading or defeating any tax due as per law because no actual taxable event had occurred since all their income was derived from illegal activities which are non-taxable according to them. The Supreme Court rejected this argument stating that gross income includes all gains derived from whatever source; legal or illegal does not matter when it comes to taxation unless specifically exempted by law. Therefore, even if the money was earned through unlawful means such as gambling (which is not exempt), it is still subject to federal taxation laws. Furthermore, regarding charges under section 371 for conspiracy against US government by defrauding IRS through deceitful practices like creation of fake entities etc., court held that these acts indeed constituted a plot against government thus affirming conviction.

In the dissenting opinion for United States v. Patrick et al., 1962, Justice Douglas argued that the Fourth Amendment's protection against unreasonable searches and seizures should extend to garbage left outside a person's home for collection. He contended that individuals have an expectation of privacy in their discarded items, as they are still within the curtilage of their homes when placed on or near public sidewalks for pickup. Furthermore, he suggested that allowing law enforcement officers to search through this refuse without a warrant could lead to abuses of power and invasions of privacy. In his view, such actions by police were akin to trespassing on private property and constituted an unwarranted intrusion into people’s personal lives.