The McEachern v. Rose case in 1937 revolved around a dispute over estate taxes. The administrator of the estate, McEachern, argued that certain property should not be included in the gross estate for tax purposes because it was transferred by the decedent before death. However, Rose, as former collector of internal revenue, insisted on its inclusion based on sections 302(c) and (d) of the Revenue Act of 1926 which state that any transfer made within two years prior to death where there is retained life interest or power are taxable unless proven they were not intended to take effect at or after death. The Supreme Court ruled against McEachern stating that since no substantial evidence had been presented proving such transfers were not meant to take effect post-death; hence they must be considered part of the gross estate subject to taxation under federal law. This ruling reinforced interpretations regarding what constitutes an individual's gross taxable estate upon their passing.

In the dissenting opinion for McEachern v. Rose, Justice Cardozo disagreed with the majority's interpretation of Section 3224 of the Revised Statutes. He argued that this statute should not be interpreted to prohibit injunctions against tax collection in all circumstances but rather only when there is no clear legal remedy available. In his view, if a taxpayer can demonstrate that they have no adequate legal recourse and will suffer irreparable harm without an injunction, courts should have discretion to issue one. This interpretation would better balance taxpayers' rights with government interests in efficient tax collection than an absolute prohibition on injunctive relief.