The U.S. Supreme Court case Holywell Corporation, et al. v. Fred Stanton Smith, etc., et al., 1991 revolved around the issue of whether a bankruptcy trustee is required to pay taxes on income generated from property held in trust during the pendency of a Chapter 11 reorganization plan. The petitioners were real estate corporations that had filed for bankruptcy under Chapter 11 and their assets were placed into an irrevocable trust with respondent Smith as trustee. When Smith did not file tax returns or pay taxes on rental income earned by properties within the trust, IRS sought payment directly from the debtors (Holywell Corp). In response, Holywell argued that they should not be liable because they no longer controlled those assets; instead it was managed by a separate legal entity -the Trustee- who failed to meet his obligations. However, after reviewing relevant sections of Bankruptcy Code and Internal Revenue Code (IRC), Supreme Court ruled against Holywell stating that while IRC does allow trustees to act as representative taxpayers in some cases but it doesn't relieve original debtor's liability for unpaid post-petition taxes incurred during administration period.

The dissenting opinion in the case of Holywell Corporation v. Fred Stanton Smith, etc., et al., 1991 argued that the majority's interpretation of bankruptcy law was incorrect and overly narrow. The dissent believed that a debtor should be allowed to appeal an order confirming their reorganization plan without having to first seek a stay from that order. They contended this approach would better align with the purpose and spirit of bankruptcy laws, which aim to provide debtors with relief while also ensuring fair treatment for creditors. The dissent further criticized the majority for failing to adequately consider how its ruling might impact future cases or create unnecessary complications within bankruptcy proceedings.