In the case of Tyler et al., Administrators, v. United States in 1929, the U.S Supreme Court ruled on a dispute regarding estate taxes. The plaintiffs were administrators of an estate who argued that certain bonds and certificates should not be included in the gross estate for tax purposes because they were owned by non-residents at the time of death. The government disagreed, asserting that these assets should be taxed as part of the decedent's gross estate since he had control over them during his lifetime and could have transferred them to others without restriction. The court sided with the government, ruling that these securities are subject to taxation under Section 402(c) of Revenue Act 1921 regardless if their owners are residents or non-residents at death time. This decision established precedent for how similar cases would be handled moving forward.

In the dissenting opinion for Tyler et al., Administrators, v. United States (1929), Justice Holmes argued that the government should not be allowed to seize property without compensation even during times of war. He disagreed with the majority's interpretation of a wartime statute which they believed gave Congress unlimited power over private property in times of war. Instead, he interpreted it as only allowing seizure when necessary and requiring just compensation afterwards. This view was based on his belief in strict adherence to constitutional rights and protections against governmental overreach into private affairs, regardless if there is an ongoing conflict or not. Furthermore, he pointed out that this case could set a dangerous precedent where governments can take away citizens' properties under vague circumstances without providing any form of reimbursement or due process.