The U.S. Supreme Court case Rohn F. Drye, Jr., et al. v. United States in 1999 revolved around the issue of whether a federal tax lien could be attached to an inheritance that was disclaimed by the taxpayer before it was received. The court ruled in favor of the Internal Revenue Service (IRS), stating that under federal law, a tax lien can indeed attach itself to after-acquired property and rights to property, including inheritances even if they are disclaimed prior to receipt by the taxpayer who owes back taxes. Rohn F. Drye owed substantial unpaid income taxes when he became entitled to receive an inheritance from his mother's estate but chose not to accept it so as not allow IRS access for debt recovery purposes; instead he directed his interest towards a family-owned corporation which would then distribute assets among its shareholders - including himself. However, this strategy did not work out as planned because according to Federal Tax Lien Act of 1966 any right or title held by delinquent taxpayers is subjectable for government liens regardless if they choose not exercise them.

In the dissenting opinion for Rohn F. Drye, Jr., et al. v. United States, Justice Clarence Thomas argued that the majority's decision was inconsistent with both federal tax law and bankruptcy law principles. He contended that under North Carolina law, a taxpayer's right to inherit is not considered property until it has been claimed; therefore, Drye had no property interest at stake when he filed for bankruptcy because he hadn't yet received his inheritance. Furthermore, Justice Thomas disagreed with the majority’s interpretation of “property” in relation to federal tax liens under Section 6321 of Internal Revenue Code (IRC). He believed this section should be interpreted narrowly as per its historical context rather than broadly as done by the majority ruling which allowed IRS claims on future interests or assets not yet in possession of taxpayers during their filing for bankruptcy.