The United States Supreme Court case, UNITED STATES v. RICE et al., 1942, revolved around the issue of whether or not a federal tax lien had priority over other creditors in a bankruptcy proceeding. The D.C Engineering Company was declared bankrupt and its assets were being distributed among its creditors when the U.S government claimed that it should be given priority due to unpaid taxes by the company. The lower courts ruled against this claim stating that under Bankruptcy Act §64a(5), unsecured claims of the US for taxes are subordinated to certain other claims. However, upon appeal, the Supreme Court reversed this decision arguing that there is no explicit provision in federal law which subordinates tax liens to other debts in bankruptcy proceedings and thus held that Federal Tax Lien has precedence over all others irrespective of state laws.

The dissenting opinion in the United States v. Rice et al., case argued that the majority's decision to allow a tax claim by the federal government against D.C. Engineering Company, Inc., was inconsistent with previous court rulings and principles of equity. The dissenters believed that allowing such a claim would unfairly prioritize the government over other creditors without clear legislative intent or statutory authority to do so. They pointed out that under normal circumstances, claims for unpaid taxes are treated like any other debt and do not receive preferential treatment in bankruptcy proceedings unless specified by law. In this case, they felt there was no legal basis for treating the government's tax claim differently from those of other creditors.