In the 1930 case of Denman, Administrator of the Estate of Charles H. Nauts, Collector of Internal Revenue v. Slayton, the United States Supreme Court addressed a dispute over inheritance tax law. The plaintiff was an administrator for an estate that had been taxed by both federal and state governments upon its transfer to heirs after death. He argued this constituted double taxation and violated constitutional protections against such practices. However, the court ruled in favor of Slayton (the defendant), upholding that both federal and state taxes could be applied to inheritances without violating any constitutional provisions or principles regarding double taxation.

In the dissenting opinion for Denman v. Slayton, Justice Stone argued that the majority's interpretation of the Revenue Act was incorrect and overly restrictive. He believed that Congress intended to provide a tax exemption for all transfers made in contemplation of death, not just those made within two years prior to death as interpreted by the majority. According to him, this broader interpretation would better align with common law principles regarding gifts causa mortis (gifts given in anticipation of imminent death). Furthermore, he pointed out inconsistencies between sections 402(c) and 302(g) of the Revenue Act which could be resolved through his proposed interpretation. In conclusion, Justice Stone disagreed with both how the majority had interpreted Congressional intent and their application of statutory construction rules.