In the case of United States v. Citizens Loan & Trust Co., Administrator, 1941, the Supreme Court examined whether a federal estate tax could be levied on an insurance policy's proceeds that were paid to a decedent’s estate. The decedent had transferred ownership and beneficiary rights of his life insurance policies to another individual three years before his death but continued paying premiums until he died. Afterward, the new owner voluntarily paid the policy proceeds into the decedent's estate. The IRS argued that since these funds ended up in the deceased person's estate due to arrangements made by him while alive, they should be subject to federal taxation as part of his gross estate under Section 302(g) of Revenue Act (1926). However, this argument was rejected by both lower courts and eventually by Supreme Court too which held that such voluntary payment does not make it taxable under mentioned section because there was no legal obligation for new owner or insurer company to pay those amounts into deceased person’s estates.

The dissenting opinion in the United States v. Citizens Loan & Trust Co., Administrator case argued that the majority's decision to allow a tax lien on an estate, prior to its distribution and before any taxes were due or assessed, was unjustified. The dissenters believed this ruling contradicted established principles of equity and fairness. They contended that it was inappropriate for the government to impose a lien on property without first determining whether there would be sufficient assets left after paying all other claims against the estate. This preemptive action by the government could potentially leave other creditors unpaid if there weren't enough resources remaining in the estate once taxes were finally calculated and levied. Furthermore, they pointed out that such actions could discourage individuals from serving as administrators of estates due to fear of personal liability for unpaid federal taxes.