In the case of Girard Trust Company, George Stevenson, William R. Verner et al. v. United States (1925), the Supreme Court ruled on a dispute over inheritance tax law and its application to trusts established by wills. The plaintiffs were executors of an estate that had set up a trust for charitable purposes in accordance with Pennsylvania state law, which exempted such trusts from taxation under certain conditions. However, federal authorities levied an inheritance tax on the trust's assets upon their transfer to beneficiaries after the death of life tenants who held interests in them during their lifetimes but did not have any power to dispose or consume those assets themselves. The main issue was whether this federal tax violated constitutional protections against double taxation since these same assets had already been taxed as part of decedent’s gross estate at his death before they were transferred into trust. The court upheld the validity of federal taxes imposed on transfers made through testamentary trusts even when they are also subject to state-level taxes due at earlier stages in administration process because different taxable events occur at each stage and thus no unconstitutional double taxation occurs.

In the dissenting opinion for Girard Trust Company, George Stevenson, William R. Verner et al. v. United States (1925), Justice Holmes argued that the majority's decision was based on a misinterpretation of Pennsylvania law and an incorrect application of federal tax law principles to this case involving estate taxes owed by a trust established under Stephen Girard’s will. He contended that under Pennsylvania law, the state had no claim to any part of Mr. Girard's estate because it was not a beneficiary but merely held legal title as trustee for charitable purposes specified in his will; therefore, there should be no deduction from its gross value when calculating federal estate tax liability since these funds were not "transferred" or "passed" to anyone upon his death according to federal tax laws' definitions of those terms at that time.