In the case of Taft, Executor v. Commissioner of Internal Revenue (1937), the U.S Supreme Court was tasked with deciding whether or not a trust's income could be taxed as part of an individual's gross income under Section 219(h) and 167(a) of the Revenue Act. The court ruled in favor of the Commissioner, stating that such income from trusts can indeed be included in an individual’s gross taxable income. This decision came about after Charles P. Taft II, executor for his father’s estate, contested against including $1 million worth revenue generated by a trust fund set up by his father into their family's overall taxable earnings. The ruling clarified how tax laws apply to trusts and estates; it established that when a grantor retains control over a trust or its assets, they are liable for taxes on any resulting income.

In the dissenting opinion for Taft v. Commissioner of Internal Revenue, Justice Cardozo disagreed with the majority's interpretation of "income" under Section 22(a) of the Revenue Act. He argued that a bequest or inheritance should not be considered income if it is merely replacing capital that was previously taxed in the hands of the decedent. According to him, such an interpretation would result in double taxation and contradict Congress' intent when drafting tax laws. Furthermore, he contended that there was no clear indication from Congress to include inheritances as taxable income under Section 22(a). Therefore, he believed that any ambiguity regarding this matter should have been resolved in favor of taxpayers rather than against them.