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The U.S. Supreme Court case White, Former Collector of Internal Revenue, v. Poor et al., Executor in 1935 revolved around the issue of estate tax liability and its calculation under federal law. The executors of a deceased individual's estate argued that certain state inheritance taxes paid should be deducted from the gross estate before calculating federal estate tax owed. However, the former collector of internal revenue disagreed with this interpretation and insisted on taxing the full value without any deductions for state taxes paid. The Supreme Court sided with the executors' argument and held that such deductions were permissible under existing legislation at that time (Revenue Act). This decision clarified how to calculate taxable estates for federal purposes when there are also applicable state-level inheritance or death duties.
In the dissenting opinion for White v. Poor, it was argued that the majority's interpretation of Section 302(c) of the Revenue Act of 1926 was incorrect. The dissenting justices believed that this section should not be interpreted to mean that a transfer intended to take effect at death is subject only to estate tax and exempt from gift tax. They contended that such an interpretation would create a significant loophole in taxation law, allowing individuals to avoid paying gift taxes by structuring transfers as testamentary gifts instead. Furthermore, they pointed out inconsistencies between this case's ruling and previous court decisions regarding similar issues in taxation law.