The U.S. Supreme Court case Anderson, Collector of Internal Revenue v. Wilson et al., Executor (1932) revolved around the issue of estate tax liability. The executors of a deceased's estate argued that certain property transferred by the decedent before his death should not be included in gross estate for federal taxation purposes because it was given as bona fide gifts and thus exempt from such taxes under applicable law at that time. However, the IRS disagreed and assessed additional taxes based on its inclusion. The Supreme Court sided with the government stating that these transfers were made "in contemplation of death" which meant they fell within taxable limits according to existing laws then governing federal estate taxation. Therefore, even though no formal or legal control over those assets existed at time of death, their transfer so close to demise indicated an intention to evade potential inheritance tax liabilities making them subject to assessment.

In the dissenting opinion for Anderson v. Wilson, Justice McReynolds disagreed with the majority's decision to allow a deduction from gross income of estate taxes paid by beneficiaries on their inheritance. He argued that this interpretation was inconsistent with the language and purpose of the Revenue Act of 1921, which he believed intended to tax net incomes rather than impose an additional burden on inheritances already subject to estate tax. According to him, allowing such deductions would result in unequal taxation among taxpayers and undermine Congress' intent when it enacted both income and estate taxes as separate entities under law. Furthermore, he contended that if Congress had intended for such deductions, they would have explicitly stated so within legislation.