In the case of Mason v. Routzahn, Collector in 1927, the Supreme Court ruled on a matter concerning federal estate tax law. The plaintiff was an executor of an estate who had paid a federal estate tax and then later discovered that they had overpaid due to an error in calculating the value of certain bonds included in the gross estate. The plaintiff sought to recover this overpayment from the defendant, who was a collector for Bureau of Internal Revenue (now known as IRS). However, under existing laws at that time, there were strict time limits within which such claims could be made - two years after payment or five years after death whichever is earlier. Unfortunately for Mason's claim it fell outside these limitations. The main issue before court was whether these statutory limitation periods applied when there has been mistake or error leading to overpayment? In its decision, Supreme Court held that indeed those limitation periods did apply even if there has been mistake or error leading to overpayment; thus ruling against Mason's claim.

In the dissenting opinion for Mason v. Routzahn, it was argued that the majority's decision to allow a tax deduction on stock losses was incorrect. The dissenting justices believed that this interpretation of the law would lead to an unfair advantage for wealthy individuals who could afford to invest in stocks and then claim large deductions if their investments failed. They also pointed out that such a ruling could potentially open up loopholes in tax laws, allowing savvy investors to manipulate their finances in order to avoid paying taxes altogether. Furthermore, they disagreed with the majority's assertion that Congress intended for these types of losses to be deductible under income tax laws.