In the case of Porter, Executrix, et al. v. Commissioner of Internal Revenue (1932), the Supreme Court was asked to determine whether a trust fund's income could be taxed as part of an individual's gross income under federal law. The court ruled that it could not because the taxpayer did not have control over or access to this money during his lifetime and therefore it should not be considered part of his taxable estate upon death. This decision clarified tax laws regarding trusts and estates, establishing that only funds directly controlled by an individual can be included in their gross income for taxation purposes.

In the dissenting opinion for Porter, Executrix, et al. v. Commissioner of Internal Revenue (1932), Justice Stone argued that the majority's decision was inconsistent with previous rulings and misinterpreted tax law. He contended that the estate should not be taxed on income earned after death because it had no opportunity to benefit from or use this income before being transferred to beneficiaries. According to Justice Stone, taxing such post-death earnings would result in double taxation since these funds would also be subject to inheritance taxes when received by heirs or beneficiaries. Furthermore, he believed that this interpretation contradicted Congress' intent when drafting relevant tax laws as they did not intend for estates to pay both income and estate taxes on the same money.