In the case of Tucker v. Alexander, Collector in 1927, the Supreme Court ruled on a dispute involving inheritance tax laws. The plaintiff, Tucker, was an heir to a trust fund established by his father who had passed away years prior. When his mother died and he received her portion of the trust fund as well, he was taxed for it under federal law. He argued that this taxation constituted double taxation since both portions were from the same original source - his father's estate - and thus violated constitutional principles against such practices. However, the Supreme Court disagreed with him and upheld lower court rulings which stated that each transfer of property is considered separately for tax purposes regardless if they originate from one common source or not. Therefore according to them there wasn't any double taxation happening here because these two transfers (one after father's death and another after mother's death) are separate taxable events.

The dissenting opinion in the case of Tucker v. Alexander, Collector argued that the majority's decision was inconsistent with previous rulings and interpretations of tax law. The dissent believed that the income from a trust should be taxed to the beneficiary only when it is distributed or made available for distribution, not when it is earned by the trust itself. They pointed out that this interpretation had been upheld in several prior cases and saw no reason to deviate from this precedent now. Furthermore, they contended that taxing undistributed income would result in double taxation once those funds were eventually distributed to beneficiaries - first at a corporate level then again at an individual level upon receipt by beneficiaries - which they viewed as unfair and contrary to legislative intent.