In the 1941 case Young v. United States, the Supreme Court ruled on a matter involving federal income tax law and its application to gifts made by a taxpayer. The petitioner, Mrs. Young, had transferred securities to her husband without receiving any consideration in return. She argued that this transfer was not subject to gift tax because it was intended as an equalization of their property rights within their marriage rather than as a gratuitous act of giving away wealth. However, the IRS disagreed and imposed gift taxes on Mrs. Young for these transfers. The Supreme Court upheld the decision of lower courts in favor of the government's position that such transfers were indeed taxable gifts under federal law at that time (Revenue Act of 1932). The court held that even if state laws recognized certain marital property rights or allowed spouses to make non-taxable transfers between each other for purposes like equalizing assets within marriage, those state-level provisions did not override or exempt taxpayers from complying with applicable federal tax laws.

In the dissenting opinion for Young v. United States, Justice Roberts argued that the majority's decision was a departure from established legal principles and precedent. He contended that the court had previously held in similar cases involving conspiracy charges that an overt act must be committed to further the conspiracy before any conviction can occur. In this case, he believed there was no evidence of such an act being committed by Young or his co-conspirators. Furthermore, he disagreed with the majority's interpretation of Congressional intent behind relevant statutes, arguing they were designed to punish actual attempts at defrauding rather than mere conspiracies without action taken towards their fulfillment. Therefore, Justice Roberts would have reversed Young’s conviction on these grounds.