The Greiner v. Lewellyn case in 1921 revolved around the issue of estate tax and its application to a life insurance policy. The executrix of Kingsley's estate, Greiner, contested that the proceeds from a life insurance policy should not be included in the gross estate for taxation purposes under the Revenue Act of 1916. Kingsley had transferred ownership and beneficiary rights of his life insurance policies to his wife before he died but continued paying premiums himself until death. The Supreme Court ruled against Greiner stating that since Mr.Kingsley retained incidents of ownership by continuing to pay premiums on these policies, they were therefore part of his gross taxable estate upon death despite having changed their formal ownership prior to his demise.

In the dissenting opinion for Greiner v. Lewellyn, it was argued that the majority's interpretation of the law was incorrect and overly broad. The dissent contended that a literal reading of Section 402(c) of the Revenue Act would not include gifts made in contemplation of death within its purview. They believed this section should only apply to transfers intended to take effect after death, which wasn't applicable in this case as Kingsley had transferred his property while still alive with no stipulations about posthumous control or benefit. Therefore, they disagreed with taxing such transfers under estate tax laws since these were essentially lifetime gifts rather than testamentary dispositions. They also expressed concern over potential double taxation if both gift taxes and estate taxes could be applied on similar transactions based on different interpretations.