The U.S. Supreme Court case Louise A. Whitcomb v. Helvering, Commissioner of Internal Revenue in 1933 revolved around the issue of taxation on gifts and estates. The petitioner, Louise A. Whitcomb, was a beneficiary to her late husband's estate which included shares from two corporations that were transferred to her without any consideration or compensation after his death in 1920. In 1924, Congress passed an act taxing such transfers retroactively back to September 8th, 1916 causing Mrs.Whitcomb's inheritance to be taxed heavily by the IRS under this new law. Mrs.Whitcomb challenged this decision arguing that it violated the Fifth Amendment as it deprived her property without due process of law and amounted to double taxation since both income tax and gift tax were levied on same property within short intervals. However,the Supreme Court ruled against Mrs.Whitcomb stating that there was no constitutional prohibition against double taxation.The court also held that retrospective application of laws is not necessarily unconstitutional unless they are arbitrary or irrational.In conclusion,the court upheld the constitutionality of applying gift taxes retrospectively.

In the dissenting opinion for Whitcomb v. Helvering, it was argued that the majority's decision to uphold a tax assessment on Louise A. Whitcomb's income from her husband’s trust fund contradicted previous court rulings and legal principles regarding taxation of income derived from property held in trust. The dissent emphasized that under established law, only those who actually receive or control the disposition of income should be liable for its taxation. In this case, Mrs. Whitcomb neither received nor controlled any part of her husband’s estate; she merely had an expectancy interest in his will which did not constitute taxable possession or enjoyment under existing laws and precedents at that time.