In the 1930 case of Goodell v. Koch, the United States Supreme Court ruled on a dispute involving tax law. The respondent, Koch, had received dividends from a corporation that were declared and payable in 1917 but not actually paid until after February 28th of that year. Under Revenue Act of 1916 and subsequent amendments in the War Revenue Act of October 3rd,1917 these dividends were subject to additional income taxes if they were paid after February 28th. However, Koch argued that since they had been declared before this date he should not be liable for extra taxation under the new laws. The Supreme Court sided with Goodell (the Collector of Internal Revenue), ruling against Koch's argument by stating that it was when dividends are made available to shareholders - rather than when they're declared - which determines their taxable status according to legislation at hand during time period involved.

In the dissenting opinion for Goodell v. Koch, Justice Holmes argued that the majority's interpretation of the tax law was incorrect and overly broad. He contended that a literal reading of the statute would not include gifts made in contemplation of death within its purview. According to him, such an interpretation would lead to absurd results as it could potentially subject any gift or transfer made by an elderly or ill person to taxation under this provision merely because they were aware of their mortality at the time they made it. He believed that Congress intended for this provision to apply only when there is clear evidence showing that a gift was specifically motivated by impending death rather than general awareness about one’s mortality.