In the case of Republic National Bank of Miami v. United States in 1992, the Supreme Court ruled that a certificate of deposit (CD) is not considered "cash" under federal forfeiture law. The case arose when two individuals attempted to launder drug money by purchasing CDs from the Republic National Bank using cash and then selling them for clean checks. When authorities discovered this scheme, they seized both the cash and CDs as part of their investigation into illegal activities related to drug trafficking. The bank argued that it was an innocent owner because it had no knowledge or involvement in any criminal activity associated with these transactions; therefore, it should be allowed to keep its property (the CD). However, the court disagreed stating that since a CD is not equivalent to cash but rather represents a promise by a bank to repay money at some future date with interest - thus making it more akin to an investment than currency - federal forfeiture laws apply which allow seizure without compensation if used in connection with illegal activities.

In the dissenting opinion for Republic National Bank of Miami v. United States, Justice Scalia argued that the majority's decision to allow a tax deduction for interest paid on loans used to purchase single-premium life insurance policies was inconsistent with both statutory language and legislative intent. He contended that Congress intended to disallow deductions for interest on indebtedness incurred or continued to purchase or carry single-premium life insurance, endowment, or annuity contracts. In his view, this interpretation is supported by the plain meaning of "indebtedness" as well as its usage in other parts of the Internal Revenue Code. Furthermore, he criticized the majority's reliance on policy considerations rather than clear statutory text and expressed concern about potential abuse if taxpayers could deduct interest payments simply by structuring their transactions in certain ways.