In the case of United States v. Hendler, Transferee in 1937, the Supreme Court ruled on a dispute involving tax liability for liquidated corporations. The respondent, Mr. Hendler was a transferee of assets from two dissolved corporations and had not paid federal income taxes on those assets. The government argued that as per Section 280(a)(1) of the Revenue Act of 1926, he should be held liable for unpaid taxes owed by these companies since he received their remaining assets upon dissolution without paying any consideration to them. The court agreed with this argument and found Mr. Hendler liable for these unpaid taxes because he was considered both an actual and beneficial transferee under section 311(a) (now section 6901(a)) which states that "the liability...shall...be assessed against such transferee." This decision clarified how tax laws apply to individuals who receive assets from dissolved corporations without providing anything in return.

In the dissenting opinion for United States v. Hendler, Transferee, 1937, it was argued that the majority's decision to hold a transferee liable for unpaid taxes of the transferor is not in line with existing tax laws and regulations. The dissenting justices believed that liability should only be imposed on those who are legally responsible according to state law or under specific provisions of federal law. They contended that there were no such provisions applicable in this case and thus disagreed with imposing liability on Hendler as a mere transferee without any legal obligation towards the debt owed by his transferor. Furthermore, they expressed concerns about setting a precedent where individuals could be held accountable for debts they did not personally incur or have legal responsibility over.