In the case of Harrison, Collector of Internal Revenue v. Bohnen, Executor et al., 1952, the U.S Supreme Court was tasked with determining whether or not a federal estate tax lien could be enforced against property that had been transferred by a decedent prior to his death but after he had incurred an unpaid federal income tax liability. The court ruled in favor of Bohnen and held that under Section 3670 of the Internal Revenue Code (IRC), a federal estate tax lien does not attach to property transferred by a taxpayer before his death for adequate consideration unless at least one year has passed since such transfer occurred. This decision clarified how IRC Section 3670 is applied when dealing with cases involving pre-death transfers and unpaid taxes.

The dissenting opinion in the case of Harrison v. Bohnen argued that the majority's decision to allow a deduction for estate taxes paid on previously taxed gifts was incorrect and not supported by law or precedent. The dissent pointed out that while there is an allowance for deductions related to administration expenses, debts, losses, charitable contributions and other specific items from gross estates before calculating federal estate tax liability; nowhere does it mention allowing a deduction for gift taxes paid on lifetime transfers. They contended that this interpretation would result in double deductions which are generally disallowed under tax laws unless specifically provided for by Congress. Furthermore, they disagreed with the majority's reliance on previous cases as those were distinguishable based on their facts and did not support such broad application of deductibility rules.