In the case of Becker, Collector of Internal Revenue v. St. Louis Union Trust Co., et al., Executor in 1935, the Supreme Court ruled on a dispute over estate taxes. The issue at hand was whether or not certain assets should be included in an individual's gross estate for tax purposes after their death. These assets were held by two trusts that had been established by the deceased during his lifetime and transferred to beneficiaries upon his death without passing through probate court proceedings. The IRS argued that these trust funds should be considered part of the decedent’s gross estate because he retained control over them until his death and therefore they should be subject to federal estate tax. The Supreme Court disagreed with this argument, ruling that since these trusts were irrevocable (meaning they could not be changed or cancelled without consent from both parties involved), they did not constitute part of the taxable gross estate under existing law at that time which only taxed property transfers made "in contemplation" of death or intended to take effect "at or after" one's demise. This decision clarified how irrevocable trusts are treated for federal taxation purposes and set precedent for future cases involving similar issues.

In the dissenting opinion for Becker v. St. Louis Union Trust Co., Justice Stone argued that the majority's interpretation of Section 302(c) of the Revenue Act was incorrect and inconsistent with its legislative history and purpose. He contended that Congress intended to tax transfers at death, not gifts made during one's lifetime, as a means to prevent estate tax evasion through last-minute transfers before death. According to him, this intent is clear from both the language used in Section 302(c) and its legislative history which shows it was enacted specifically to close loopholes allowing such evasion tactics. Therefore, he disagreed with the majority’s decision that Mrs. McGehee’s transfer of property should be taxed under this section because she had retained an income interest until her death; instead asserting it should have been treated as a gift inter vivos (during life), not causa mortis (because of death).