The Estate of Spiegel v. Commissioner of Internal Revenue case in 1948 revolved around the issue of whether or not a gift tax should be imposed on certain transfers made by the decedent, Mr. Spiegel, during his lifetime. The Supreme Court ruled that these transfers were indeed taxable gifts under Section 1000 of the Internal Revenue Code because they were not made for an adequate and full consideration in money or money's worth. The court found that while there was some benefit to Mr. Spiegel from these transactions, it did not constitute sufficient consideration to avoid taxation as a gift since it didn't equate to the value transferred out by him.

In the dissenting opinion for Estate of Spiegel et al. v. Commissioner of Internal Revenue, it was argued that the majority's interpretation of Section 811(c) and (d) in relation to estate tax law was incorrect. The dissenting justices believed that these sections should not be read as separate entities but rather as a whole, with each part complementing and explaining the other parts. They contended that this holistic reading would lead to a different conclusion than what the majority had reached regarding whether or not certain property could be included in gross estate calculations for taxation purposes after death. Furthermore, they disagreed with how much weight was given to legislative history by the majority when interpreting these laws; instead arguing that more emphasis should have been placed on statutory language itself.