In the case of Blundell, Executor, et al. v. Wallace in 1924, the Supreme Court examined a dispute over an inheritance and its tax implications. The decedent had left his estate to his wife for her lifetime use with the remainder going to their children upon her death. However, she renounced this provision of the will and elected instead to take a statutory share of one-third outright ownership under New York law at that time. The question before the court was whether or not this election constituted a taxable transfer under federal estate tax laws. The Supreme Court ruled that it did constitute such a transfer because it represented an increase in beneficial interest beyond what was provided by the will itself - essentially she gained more control over more property than originally intended by her husband's will due to state law provisions allowing her choice. This decision established important precedent regarding how changes made posthumously can affect taxation on estates and inheritances.

In the dissenting opinion for Blundell v. Wallace, it was argued that the majority's decision failed to adequately consider the rights of a deceased person's estate and its beneficiaries. The dissenting justices believed that there should be no difference in how an individual’s property is treated before or after their death, as long as they had clearly expressed their wishes regarding its distribution. They contended that if someone has made clear provisions for their property upon death, those instructions should be respected and upheld by law regardless of any subsequent changes in circumstances or relationships among potential beneficiaries. This view emphasizes respect for personal autonomy and private property rights over other considerations such as fairness or equity among heirs.