The U.S. Supreme Court case Harrison, Collector of Internal Revenue v. Northern Trust Co., et al., Executor (1942) revolved around the issue of estate taxation and the interpretation of Section 302(g) in the Revenue Act of 1926. The court had to decide whether certain property transferred by a decedent should be included in his gross estate for federal tax purposes or not. The decedent had created an irrevocable trust during his lifetime, retaining income rights but relinquishing all control over principal assets which were later sold by trustees without any involvement from him; he died within two years after this sale occurred. The IRS argued that since these transactions happened within two years before death, they should be considered as part of his gross estate under Section 302(g). However, the Supreme Court disagreed with this view and ruled against it stating that once control was completely surrendered over those assets during life time itself then such transfers cannot be brought back into calculation while determining value for tax purpose even if death occurs shortly thereafter.

In the dissenting opinion for Harrison v. Northern Trust Co., Justice Frank Murphy argued that the majority's interpretation of Section 302(g) of the Revenue Act was incorrect and unjustly penalized taxpayers who had made legitimate transfers before death. He believed that Congress intended to tax only those transfers made in contemplation of death, not all transfers within two years prior to death regardless of intent or circumstances. Furthermore, he pointed out that this broad interpretation could lead to absurd results where even gifts given in good health long before any thought of impending demise would be taxed as if they were testamentary dispositions simply because the donor happened to die unexpectedly within two years. This, according to him, is contrary both to common sense and justice.