In the case of Colorado National Bank et al., Executors, v. Commissioner of Internal Revenue in 1938, the Supreme Court had to decide on a matter related to estate tax law. The issue at hand was whether or not certain securities that were part of an estate should be valued at their market price when they were received by the executors or if they should be valued based on their worth when they were finally distributed to beneficiaries. The court ruled in favor of the Commissioner of Internal Revenue and held that for purposes of federal taxation, assets must be appraised as per their value at time distribution rather than receipt. This decision clarified how asset valuation is determined under federal tax law and set a precedent for future cases involving similar issues.

In the dissenting opinion for Colorado National Bank et al., Executors, v. Commissioner of Internal Revenue, 1938, it was argued that the majority's decision to include in gross estate tax calculation a life insurance policy owned by the deceased but payable to his wife is incorrect. The dissenting justices believed this interpretation contradicted both legislative intent and previous court rulings which excluded such policies from taxation under federal law. They contended that Congress intended only those assets controlled by an individual at their death be subject to estate taxes; since control over the life insurance policy had been transferred prior to death, it should not be included in taxable property calculations. Furthermore, they pointed out inconsistencies between this ruling and earlier cases where similar circumstances were treated differently. Thus, they disagreed with expanding tax liability beyond what was explicitly stated in legislation or established through precedent.