The Phillips et al., Executors, v. Commissioner of Internal Revenue case in 1930 revolved around the issue of estate taxation. The executors of a deceased's estate contested an additional tax assessment made by the Commissioner of Internal Revenue on grounds that it was incorrectly calculated based on the value at death rather than six months later as stipulated by law. They argued that certain securities included in the gross estate had depreciated significantly within this period and should be valued accordingly to reduce their tax liability. However, the Supreme Court ruled against them stating that while some assets may indeed fluctuate in value over time, for purposes of consistency and fairness in taxation, all property must be appraised at its fair market value at date-of-death unless specifically provided otherwise under federal law.

In the dissenting opinion for Phillips et al., Executors, v. Commissioner of Internal Revenue, Justice Stone argued that the majority's interpretation of Section 302(c) was incorrect and overly narrow. He believed that this section should be interpreted to include all transfers made in contemplation of death, not just those intended to take effect at or after death as determined by the majority. According to him, such a restrictive reading would exclude many transactions clearly meant to fall within its scope from taxation under estate tax laws. Furthermore, he disagreed with the majority's view that Congress did not intend for gifts inter vivos (gifts given during one’s lifetime) which are made in contemplation of death to be taxed under Section 302(c). He contended that there is no clear evidence supporting this assertion and it contradicts established principles governing statutory construction.