Supreme Court of the United States

Drye v. United States

January 12, 2000528 U.S. 49

Summary

The Supreme Court affirmed the Eighth Circuit, holding that a taxpayer's disclaimer of an inheritance under state law does not prevent federal tax liens from attaching to that interest. The Court ruled that while state law defines the rights, federal law determines whether those rights constitute property under 26 U.S.C. § 6321, and Drye's control over the inheritance qualified as such.