In the 1940 case United States v. Stewart, the Supreme Court ruled on a matter of tax evasion. The defendant, Robert E. Stewart, was convicted for evading taxes by not reporting income he had earned from illegal activities (namely bootlegging). He appealed his conviction to the Supreme Court arguing that forcing him to report this income would violate his Fifth Amendment right against self-incrimination as it would require him to disclose illegal activity. However, the court rejected this argument and upheld his conviction with an unanimous decision stating that while individuals cannot be compelled to provide information which may incriminate them in criminal proceedings; they are still required under law to pay taxes on all forms of income - legal or otherwise.

In the dissenting opinion for United States v. Stewart, Justice Frank Murphy argued that the majority's decision to uphold Stewart's conviction under a federal law prohibiting theft from interstate shipments was incorrect. He contended that there was insufficient evidence to prove beyond reasonable doubt that Stewart knew he was stealing from an interstate shipment, which is necessary for conviction under this specific statute. According to Justice Murphy, mere possession of stolen goods does not automatically imply knowledge about their origin or nature; therefore it cannot be assumed without concrete proof that Stewart knowingly committed a federal crime. Furthermore, he expressed concern over potential misuse of such broad interpretations in future cases and emphasized on upholding principles of fair trial and due process rights.