The U.S. Supreme Court case of Ephraim Lederer, Collector of Internal Revenue for the First District of the State of Pennsylvania v. Fidelity Trust Company in 1924 revolved around a dispute over estate taxes. The issue at hand was whether or not certain assets could be included in an individual's gross estate for tax purposes after their death. In this particular case, it involved bonds owned by a deceased person that were held by another party as collateral security on loans made to him during his lifetime and which had been repaid before his death but were still being held due to other obligations he owed them unrelated to those loans. The court ruled against Lederer, stating that these bonds should not have been included in the gross estate because they weren't part of the decedent’s property at time of death since they were no longer serving as collateral for any debt he owed when he died; hence, they couldn’t be used towards paying off any potential inheritance tax liability.

In the dissenting opinion for Ephraim Lederer, Collector of Internal Revenue for the First District of Pennsylvania v. Fidelity Trust Company, Justice McReynolds expressed his disagreement with the majority's interpretation of Section 402(c) of the Revenue Act. He argued that this section was intended to tax only those transfers made in contemplation of death or intended to take effect at or after death. The justice believed that Congress did not intend to impose a tax on gifts inter vivos (gifts given during one's lifetime), which are entirely disconnected from any thought of demise and do not diminish what would otherwise pass by will or descent. Therefore, he contended that such an interpretation is inconsistent with both legislative intent and previous court decisions regarding similar matters.