In 1942, a woman inherited property worth $33,650, its value rose to $95,000, then a mother-son ownership arrangement triggered a US estate-tax dispute

The dispute reached the US Court of Appeals for the Fourth Circuit, which ruled on November 1, 1967, in favour of the Internal Revenue Service (IRS). The court upheld a Tax Court decision that included nearly the entire value of the jointly owned property in Peters' taxable estate, after accounting for her son's qualifying contribution.