In the United States v. Estate of Francis J. Romani et al., 1997, the Supreme Court ruled on a dispute over priority between federal tax liens and private creditor's security interests under Pennsylvania law. The Internal Revenue Service (IRS) had filed tax liens against Francis J. Romani for unpaid taxes after Citizens National Bank had already secured a mortgage on his property as collateral for loans he owed them. When Romani died, both parties claimed rights to proceeds from selling his estate’s assets. The court held that under Federal Tax Lien Act of 1966, state law determines whether an interest in property is sufficiently extant or choate to be considered "property" or "rights to property". Therefore, it was determined that since Citizen National Bank's lien was specific and perfected before IRS filed its notice of federal tax lien; thus it took precedence over the later-filed federal tax lien. This decision clarified how local laws interact with federal ones when determining which creditors have first claim on debtors' properties in cases involving competing claims by private lenders and government agencies seeking unpaid taxes.

In the dissenting opinion for United States v. Estate of Francis J. Romani, Justice Ginsburg argued that the majority's interpretation of federal tax lien law was incorrect and overly broad. She contended that Pennsylvania's "relation-back" doctrine should apply in this case, which would allow a creditor with a judgment lien to have priority over other creditors from the time when their claim initially arose, rather than from when they obtained judgement. This would mean that Citizens Bank’s mortgage on Romani’s property could take precedence over later federal tax liens because it originated before those liens were assessed by IRS. Furthermore, she pointed out inconsistencies between this decision and previous Supreme Court rulings regarding similar issues about competing claims on debtor's assets under state laws versus Federal Tax Lien Act (FTLA). In her view, FTLA does not automatically grant superiority to all federal tax liens but allows room for certain exceptions based on local rules or equitable principles.