In the case of Pagel, Administrator v. MacLean, Administrator (1930), the U.S Supreme Court was tasked with determining whether a state could tax an inheritance that included federal bonds. The decedent had left behind an estate in Wisconsin which contained federal bonds among other assets. Under Wisconsin law at the time, inheritances were subject to taxation and this applied to all assets within an estate including any federal bonds it may contain. The administrators of the estate argued that under Federal law these bonds were exempt from state taxation and thus should not be included when calculating inheritance taxes owed by beneficiaries of the will. However, both lower courts ruled against them stating that while individual states cannot directly tax federal property such as government-issued securities or salaries paid to its employees; they can indirectly do so through their power to levy death duties on estates containing such properties. Upon appeal, The US Supreme Court upheld these rulings concluding that although direct taxation on federally issued securities is prohibited under Federal Law; indirect forms like those levied upon inheritances are permissible since they don't interfere with any governmental functions nor discriminate against holders of such securities.

The dissenting opinion in the case of Pagel v. MacLean disagreed with the majority's decision to uphold a lower court ruling that allowed for an estate administrator to be sued by another estate administrator. The dissent argued that this interpretation was contrary to common law principles, which traditionally do not allow for suits between executors or administrators of estates unless there is a specific statutory provision allowing it. They contended that such lawsuits could lead to unnecessary litigation and potential abuse, as well as potentially infringing on the rights of beneficiaries under the wills or intestacy laws. Furthermore, they believed that any disputes between executors or administrators should be resolved within probate proceedings rather than through separate civil actions.