In the case of United States v. Sweet, Administrator of Sweet (1917), the Supreme Court was tasked with determining whether or not a tax assessment on an estate could be considered valid if it was made after the death of the individual in question but before their property had been transferred to their heirs. The court ruled that such a tax assessment is indeed valid and can be collected from those who inherit said property. This decision established that federal inheritance taxes are due at time of death, regardless when they are assessed or collected.

In the dissenting opinion for United States v. Sweet, it was argued that the federal government did not have jurisdiction over a murder committed by an Indian on reservation land. The dissenting justices believed that Congress had no authority to pass laws governing crimes committed within tribal territories unless explicitly granted such power by the Constitution or through treaties with individual tribes. They contended that allowing federal prosecution in this case would undermine tribal sovereignty and self-governance, as well as violate principles of federalism and separation of powers enshrined in the Constitution. Furthermore, they disagreed with majority's interpretation of relevant statutes and historical precedents related to Indian affairs.