In the 1915 case of White, Receiver of Cowardin, Bradley, Clay & Co. v. United States, the Supreme Court dealt with a dispute over tax liability for a bankrupt company. The receiver (White) argued that he should not be held liable for taxes owed by the insolvent corporation because those debts were incurred before his appointment and thus outside his control or responsibility. However, the government contended that as receiver he was responsible for all corporate liabilities regardless of when they arose. The court sided with the government's interpretation and ruled against White in an unanimous decision written by Justice Joseph McKenna. It found that under federal law receivers are indeed liable for unpaid taxes even if these obligations predate their appointments since they step into the shoes of corporations upon assuming their roles and inherit both assets and liabilities alike.

In the dissenting opinion for White, Receiver of Cowardin, Bradley, Clay & Co. v. United States (1915), Justice Oliver Wendell Holmes Jr., disagreed with the majority's interpretation of a tax law that led to a ruling against Cowardin, Bradley, Clay & Co. He argued that the language and intent of Congress in creating this law was not to penalize companies undergoing bankruptcy proceedings by taxing them on debts they were unable to pay due to their financial situation. Instead he believed it should be interpreted as only applying taxes on actual income received by such entities rather than theoretical income from unpaid debts which may never materialize due to insolvency or other reasons beyond control of these firms. This view emphasized fairness and practicality over strict literal interpretation without considering real-world implications for struggling businesses trying hard enough already just surviving through tough times like bankruptcy process itself.