The Northeastern Pennsylvania National Bank & Trust Co., Executor v. United States case in 1966 revolved around the issue of estate tax valuation. The bank, as executor of a deceased's will, argued that certain bonds should be valued at their market price on the date of death rather than their redemption value for purposes of federal estate taxation. However, the Supreme Court ruled against this argument stating that these bonds were to be included in gross estate at their face amount plus accrued interest if they are redeemable by an executor before maturity without any substantial restriction or limitation. This decision was based on Section 2031(a) and (b) of Internal Revenue Code which defines "gross estate" and provides rules for valuing property respectively.

In the dissenting opinion for Northeastern Pennsylvania National Bank & Trust Co. v. United States, Justice Harlan argued that the majority's interpretation of Section 811(c) of the Internal Revenue Code was incorrect and inconsistent with its legislative history. He contended that Congress intended to tax only those interests in property which were actually transferred at death, not those merely terminable at death as interpreted by the majority. According to him, this misinterpretation led to an unjust result where a decedent’s estate was taxed on assets it never possessed or controlled simply because they could have been included if certain contingencies had occurred before his death. Furthermore, he criticized the court's reliance on prior decisions involving different statutory provisions and factual circumstances as inappropriate precedents for interpreting Section 811(c). In conclusion, Justice Harlan believed that under proper construction of Section 811(c), no part of Mrs.Tripp's trust interest should be included in her husband’s gross estate.