In the case of Duignan v. United States, 1926, the Supreme Court ruled on a matter concerning inheritance tax law. The plaintiff, Duignan was an alien and resident of Great Britain who inherited property in Illinois from his brother's estate. He contested that he should not be subjected to pay taxes under the Revenue Act of 1918 because it did not apply to aliens residing abroad at time of death or when succession took place. However, the court held that this act applied regardless if one is a citizen or non-citizen and whether they reside within or outside U.S borders at time of death or succession. Therefore, Duignan was required to pay federal estate taxes on his inherited property located in Illinois despite being a foreigner living abroad.

In the dissenting opinion for Duignan v. United States, it was argued that the majority's decision to deny citizenship to children born abroad to American parents who had not resided in the U.S. was unjust and inconsistent with previous rulings on similar cases. The dissenting justices believed that a child of an American citizen should be considered a natural-born citizen regardless of where they were born or whether their parent had lived in America before their birth. They contended that denying such individuals citizenship would create unnecessary hardship and could potentially leave them stateless if no other country recognized them as citizens either due to similar laws regarding parental residency requirements for nationality determination at birth.