Prout v. Starr, a 1902 U.S Supreme Court case, revolved around the issue of land ownership and property rights in Oklahoma. The plaintiff, Prout, claimed that he had purchased a tract of land from an individual who was part of the Creek Nation and held it under tribal law before Oklahoma became a state. However, after statehood was established in Oklahoma, another party named Starr contested this claim to ownership by arguing that federal laws governing Indian lands superseded any previous agreements made under tribal law. The court ruled in favor of Prout stating that his purchase was valid because at the time when he bought the land there were no specific restrictions on alienation imposed by Congress on such transactions within these territories. Therefore even though subsequent legislation might have prohibited such sales without government approval or supervision; those rules did not apply retroactively to invalidate prior legal arrangements.

In the dissenting opinion for Prout v. Starr, the justice argued that the majority's decision to uphold a tax on inheritances was inconsistent with previous rulings and interpretations of constitutional law. The justice contended that an inheritance is not income but rather a transfer of property rights from one individual to another upon death. Therefore, it should not be subject to taxation under federal law as this would constitute double taxation - once when the deceased earned it and again when their heir received it. This interpretation, according to the dissenting justice, aligns more closely with principles of fairness and equity in tax policy than does treating inheritances as taxable income.