In the case of Blacklock, Executor of Rinaldo P. Smith v. United States (1907), the U.S Supreme Court dealt with a dispute over an inheritance tax claim by the federal government. The decedent, Rinaldo P. Smith, had transferred bonds to his children prior to his death and these were not included in his estate for taxation purposes at the time of his demise. However, after Mr. Smith's death, it was discovered that he still held some control over these bonds during his lifetime which led to their inclusion in calculating inheritance taxes due from Mr.Smith’s estate. The executor of Mr.Smith's will contested this decision arguing that since no income or interest was derived from those bonds during Mr.Smith’s lifetime they should not be considered part of taxable assets under existing law.The court ruled against him stating that even though no direct benefit may have been received by Mr.Smith from those bonds while alive,the fact he retained control meant they were indeed part of taxable assets.This ruling established a precedent on how transfers made before death but controlled by decedents are treated for tax purposes.

In the dissenting opinion for Blacklock v. United States, Justice Harlan argued that the Court's majority decision was incorrect in its interpretation of a clause in an 1851 treaty between the U.S. and Choctaw Indians. The clause stated that any land not allotted to individual members would be sold by the government and proceeds distributed among tribe members. The majority held this meant only those who were tribal members at treaty signing could benefit from such sales; however, Harlan disagreed, arguing it should also include individuals who became tribal members after 1851 but before lands were sold off (like Rinaldo Smith). He believed there was no language in the treaty explicitly excluding these later-joining individuals from benefiting from land sales, thus they should have been considered rightful beneficiaries under law.