In the case of United States v. William F. Hill, et ux., 1992, the Supreme Court examined whether a taxpayer could deduct interest on money borrowed to purchase single premium life insurance policies before they were deemed taxable under Section 264(a)(3) of the Internal Revenue Code in 1986. The Hills had purchased these policies in December 1985 and claimed deductions for policy loan interest paid from then until April 15, 1987. However, their claim was denied by the IRS which argued that such deductions were not allowed after August 1st, as per an amendment made to Section (a)(3). The Tax Court sided with the IRS but upon appeal to Ninth Circuit court reversed this decision stating that Congress intended for taxpayers who entered into transactions before August should be exempted from new rules till April next year. This led government to seek certiorari review by Supreme Court where it held that while generally amendments are applied prospectively unless stated otherwise; here legislative history indicated clear intent of Congress for immediate application post-August thus denying any deduction claims beyond this date.

The dissenting opinion in the case of United States v. William F. Hill, et ux., 1992 argued that the majority's decision to uphold a tax lien against property held by tenants by entirety was incorrect and inconsistent with previous rulings on similar matters. The dissent believed that federal law should not supersede state laws regarding property rights unless explicitly stated in legislation, which it wasn't in this case. They contended that allowing such an intrusion into state law could lead to unpredictable results and undermine states' ability to regulate their own affairs effectively. Furthermore, they disagreed with the majority's interpretation of "property" or "rights to property," arguing instead for a narrower definition based on traditional common-law principles rather than broad statutory language.