In the United States v. Hemme case of 1985, the Supreme Court ruled in favor of the government regarding a tax dispute. The Hemmes had received a gift of land and were required to pay federal gift taxes on it. They argued that they should be allowed an additional deduction under Section 2523(e) of the Internal Revenue Code because they would use part of this land for their personal residence within a stipulated period after receiving it. However, both lower courts and ultimately, the Supreme Court disagreed with them stating that such deductions only apply when property is transferred between spouses as clearly stated in Section 2523(e). Therefore, since there was no spousal transfer involved here but rather an inter-family one (from parents to son), no extra deduction could be claimed by Hemmes under this section.

In the dissenting opinion for United States et al. v. Hemme et al., Justice Blackmun disagreed with the majority's interpretation of the tax code, arguing that it was inconsistent with Congress' intent when drafting the legislation. He contended that a literal reading of Section 2032A of Internal Revenue Code would lead to an absurd result, which is not what Congress intended when they enacted this provision to provide estate tax relief for family farms and businesses. According to him, such a narrow interpretation would unfairly penalize taxpayers who had made inter vivos transfers before their death by denying them any benefit from this provision while rewarding those who held onto their property until death. He also criticized the majority's reliance on legislative history in interpreting this statute as selective and misleading because it ignored other relevant parts of Congressional record showing lawmakers' concern about preserving family farms and businesses through favorable tax treatment.