In the case of Guggenheim v. Rasquin, Administratrix (1940), the U.S. Supreme Court was tasked with determining whether or not a federal estate tax could be levied on an annuity that had been purchased by a deceased husband for his wife from community property funds. The court ruled in favor of Rasquin, stating that since the annuity was bought with community property funds and thus belonged to both spouses equally under New York law, only half its value should be included in the gross estate for federal taxation purposes upon death of one spouse. This decision established important precedent regarding how assets acquired through community property are treated when it comes to federal taxes.

In the dissenting opinion for Guggenheim v. Rasquin, it was argued that the majority's decision to allow a tax deduction on an estate's value due to future charitable donations was incorrect. The dissenting justices believed this interpretation of the law could lead to potential abuse and manipulation by wealthy individuals looking to avoid taxes. They contended that allowing such deductions would essentially mean giving these individuals control over public funds without any governmental oversight or regulation, which they saw as problematic and contrary to the intent of taxation laws. Furthermore, they disagreed with the majority’s view that Congress intended for such deductions when drafting relevant legislation.