In the 1934 case Bull, Executor v. United States, the Supreme Court ruled on a matter of estate taxation. The issue at hand was whether an income tax assessment against a decedent could be collected from his estate after his death and if this constituted double taxation under the Fifth Amendment's Due Process Clause. The court held that it did not constitute double taxation because inheritance taxes and income taxes are fundamentally different in nature - one is levied upon property passing by will or intestacy while the other is imposed upon profit derived from use of capital. Therefore, they do not fall within the same class for purposes of constitutional prohibition against double taxation.

In the dissenting opinion for Bull v. United States, Justice McReynolds disagreed with the majority's view that a tax assessment on an estate could be retroactively applied without violating the Fifth Amendment of the Constitution. He argued that this was not merely a procedural change but rather one that substantively altered taxpayers' obligations and liabilities. According to him, such retrospective legislation is inherently unfair as it disrupts settled expectations and undermines confidence in law's stability. Furthermore, he contended that allowing Congress to enact laws affecting past transactions would lead to arbitrary government action and potential abuse of power. Therefore, he believed this type of retroactive taxation violated due process rights under the Constitution.