The Supreme Court case Helvering v. Safe Deposit & Trust Co. of Baltimore in 1941 revolved around the issue of taxation on trust income. The Commissioner of Internal Revenue, Guy T. Helvering, argued that the entire net income from a trust established by Maryland resident Mary Garrett should be taxed under federal law as it was not distributed to any beneficiaries during the tax year in question but accumulated for future distribution instead. The trustee and beneficiary contested this claim, arguing that only part of the income could be taxed because some had been set aside for charitable purposes which were exempt from federal taxes under Maryland state law. The court ruled in favor of Helvering, stating that since no portion was actually paid out or permanently set aside for charity within the taxable year itself, all undistributed net income remained subject to federal taxation regardless if they are intended for future charitable contributions later on.

In the dissenting opinion for Helvering v. Safe Deposit & Trust Co., Justice Roberts argued that the majority's decision was a departure from established principles of taxation and trust law. He contended that under Maryland law, which governed this case, the income in question belonged to the life tenant (the person who receives benefits from a trust during their lifetime), not to the remaindermen (those who receive benefits after the life tenant's death). Therefore, he believed it should be taxed as such. Furthermore, he disagreed with how his colleagues interpreted relevant sections of federal tax code; they saw them as allowing taxation on future interests while he did not believe these provisions applied here. In essence, Roberts felt that taxing someone on income they may never receive contradicted both state laws and common sense.