In the case of United States v. Goelet (1913), the Supreme Court ruled on a dispute involving inheritance tax law. Robert Goelet, a U.S citizen living in New York, inherited property from his father who was also a U.S citizen but resided in Paris at the time of his death. The government argued that since both were American citizens, an inheritance tax should be applied to all properties regardless of their location. However, Goelet contended that he shouldn't have to pay taxes on foreign assets as they weren't within US jurisdiction. The court sided with Goelet and held that federal estate taxes could not be levied against property located outside the United States even if both parties involved are American citizens. The ruling emphasized respect for international boundaries and sovereignty when it comes to taxation matters.

In the dissenting opinion for United States v. Goelet, Justice Holmes disagreed with the majority's interpretation of international law and its application to this case. He argued that the court had overstepped its bounds by interpreting an ambiguous treaty provision in a way that favored U.S. interests without sufficient regard for principles of international comity or respect for foreign sovereignty. In his view, it was not clear from the text of the treaty whether it intended to grant exclusive jurisdiction to American courts over all disputes involving American citizens abroad, as opposed to merely providing them with additional protections under local law. Therefore, he would have deferred to French authorities' decision on how best to handle such matters within their own territory rather than imposing an American-centric solution unilaterally.