In the Spreckels v. Commissioner of Internal Revenue case in 1941, the Supreme Court dealt with issues related to estate tax law and property rights. The dispute arose after Claus A. Spreckels' death when his son, Adolph B. Spreckels, claimed that he had a vested remainder interest in his father's trust fund which should not be included in his father’s gross estate for federal taxation purposes under Section 302(d) of the Revenue Act of 1926. However, both lower courts ruled against him stating that it was subject to an "ascertainable standard" based on maintenance and support which made it taxable as per Section 811(c). When appealed to the Supreme Court, they affirmed this decision by holding that since Adolph's right to income from the trust could be altered or terminated by events such as remarriage or death; thus making it contingent rather than absolute - hence taxable.

In the dissenting opinion for Spreckels v. Commissioner of Internal Revenue, Justice Roberts disagreed with the majority's ruling that a gift tax could be imposed on transfers made in contemplation of death. He argued that such an interpretation was inconsistent with Congress' intent when it enacted the gift tax statute and would lead to double taxation since estate taxes were also levied upon death. Furthermore, he contended that there was no clear evidence indicating whether or not Mr. Spreckels had transferred his property in anticipation of his demise; therefore, imposing a gift tax based on this assumption was unjustified. Lastly, he pointed out inconsistencies within the court’s decision itself regarding what constitutes “contemplation of death,” making its application arbitrary and uncertain.