The U.S. Supreme Court case Trust Under the Will of Bingham et al. v. Commissioner of Internal Revenue in 1944 revolved around a dispute over estate tax liability for trusts established under Massachusetts law by William Bingham, who died in 1930. The issue was whether the value of property transferred to his wife and daughter should be included in his gross estate for federal tax purposes or not. The court ruled that since Mr.Bingham retained control over the trust's income during his lifetime, it should be considered part of his gross estate upon death and therefore subject to federal taxation as per Section 302(c) and (d) of the Revenue Act of 1926.

In the dissenting opinion for the case of Trust Under The Will Of Bingham et al. v. Commissioner of Internal Revenue, Justice Robert H. Jackson disagreed with the majority's interpretation of tax law and its application to trusts established under a will. He argued that income from property held in trust should not be taxed as part of an estate but rather as individual income once it is distributed to beneficiaries or used for their benefit, even if they have no legal claim on it until after death taxes are paid. According to him, this approach would better reflect economic realities and prevent double taxation since both estates and individuals pay taxes on their incomes.