In the case of Kahn et al., Executors of Wolff, v. United States (1921), the Supreme Court ruled on a dispute regarding estate taxes. The executors of the estate of Benjamin Wolff argued that certain bonds and certificates should not be included in his gross estate for tax purposes because they were owned by foreign corporations and located outside U.S. jurisdiction at the time of his death. However, since Wolff was a resident and citizen at his death, all property he owned or had interest in - regardless if it's within or outside U.S.- is taxable under federal law according to Revenue Act 1916 section 202(b). The court held that these assets were indeed subject to taxation as part of Wolff’s gross estate despite their location abroad.

In the dissenting opinion for Kahn et al., Executors of Wolff, v. United States, Justice McReynolds disagreed with the majority's interpretation of Section 2(a) of the Revenue Act of 1916. He argued that it was not intended to tax gifts made by a deceased person before their death. The justice believed that Congress did not intend to levy an additional estate tax on property transferred as a gift during one's lifetime and had already been subjected to taxation under existing laws at the time they were given away. He further contended that if Congress wanted such transfers included in gross estates for purposes of calculating estate taxes, it would have explicitly stated so in clear language within legislation itself rather than leaving it open-ended or ambiguous for judicial interpretation.