Rohn F. Drye, JR., et al. v. United States (528 U.S. 49)
U.S. Supreme Court · decided December 7, 1999 · Supreme Court Database (Spaeth)
- Citation
- 528 U.S. 49 · 120 S. Ct. 474
- Decided
- December 7, 1999
- Term
- October Term 1999
- Vote
- 9–0
- Majority author
- Justice Ginsburg
- Issue area
- Federal Taxation
- Disposition
- Affirmed
- Outcome
- Petitioning party lost
- Ideological direction
- Liberal
Opinion excerpt
Justice Ginsburg delivered the opinion of the Court. This ease concerns the respective provinces of state and federal law in determining what is property for purposes of federal tax lien legislation. At the time of his mother’s death, petitioner Rohn F. Drye, Jr., was insolvent and owed the Federal Government some $825,000 on unpaid tax assessments for which notices of federal tax liens had been filed. His mother died intestate, leaving an estate with a total value of approximately $233,000 to which he was sole heir. After the passage of several months, Drye disclaimed his interest in his mother’s estate, which then passed by operation of state law to his daughter. This case presents the question whether Drye’s interest as heir to his mother’s estate constituted "property” or a “righ[t] to property” to which the federal tax liens attached under 26 U. S. C. § 6321, despite Drye’s exercise of the prerogative state law accorded him to disclaim the interest retroactively. We hold that the disclaimer did not defeat the federal tax liens. The Internal Revenue Code’s prescriptions are most sensibly read to look to state law for delineation of the taxpayer’s rights or interests, but to leave to federal law the determination whether those rights or interests constitute "property” or "rights to property” within the meaning of § 6321. "[Ojnee it has been determined that state law…
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