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DRYE v. UNITED STATES

No. 98-1101.

528 U.S. 49 (1999)

DRYE et al. v. UNITED STATES

United States Supreme Court.

Decided December 7, 1999.

Attorney(s) appearing for the Case

Daniel M. Traylor argued the cause and filed a brief for petitioners.

Kent L. Jones argued the cause for the United States. With him on the brief were Solicitor General Waxman, As- sistant Attorney General Argrett, Deputy Solicitor General Wallace, David I. Pincus, and Anthony T. Sheehan.

Ginsburg, J., delivered the opinion for a unanimous Court.

Justice Ginsburg, delivered the opinion of the Court.

This case 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 $325,000 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...

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