In the case of Coudert, Administrator v. United States (1899), the U.S. Supreme Court was tasked with determining whether a claim against an estate for unpaid taxes could be considered a debt under New York law and thus have priority over other claims against the estate. The court ruled that tax obligations to the federal government did indeed constitute debts under state law, even if they were not recognized as such by local statutes or judicial decisions. Therefore, these tax liabilities should be given precedence over other claims on an insolvent estate in accordance with federal laws governing bankruptcy proceedings and distribution of assets among creditors. This decision reinforced the principle that federal laws supersede conflicting state laws when it comes to matters within Congress's constitutional purview.

In the dissenting opinion for Coudert, Administrator v. United States (1899), Justice Harlan argued that the majority's decision to deny Mr. Coudert's claim was unjust and inconsistent with previous court rulings. He believed that Mr. Coudert should be compensated for his services as a lawyer in recovering property seized by the U.S government during the Civil War because he had been promised payment from any recovery made on behalf of Mrs. Gaines, who owned said property before it was confiscated under war measures act due to her husband’s Confederate ties. Justice Harlan pointed out that although Mrs.Gaines died before she could receive compensation, this did not negate Mr.Coudert’s right to his fees since he had already completed substantial work towards securing restitution when she passed away; hence according to him, denying such would amount to an unfair enrichment of state at expense of private individuals. He further criticized majority’s reliance on technicalities like absence of formal contract between parties or lack of explicit congressional approval for such payments which were not required under existing laws then and emphasized instead on principles like equity and fairness in interpreting law.