In the case of United States v. Sotelo Et Ux., the Supreme Court ruled that a tax lien imposed by the federal government could be applied to community property, even if only one spouse was responsible for incurring the tax debt. The court held that under California law, both spouses were equally liable for debts incurred during marriage and thus, all community property was subject to seizure by creditors regardless of which spouse had incurred the debt. This decision affirmed an earlier ruling made by a lower court and rejected arguments from Mr. Sotelo who claimed his wife's separate earnings should not be considered as part of their joint assets when calculating their total taxable income.

In the dissenting opinion for United States v. Sotelo Et Ux., Justice Brennan, joined by Justices Stewart and Marshall, argued that the majority's interpretation of Section 6331(a) was incorrect. They believed that this section does not authorize a levy on property or rights to property unless they belong to the taxpayer who is liable for unpaid taxes. The dissenting justices pointed out that in this case, Mr. Sotelo’s wages were assigned to his wife as part of their divorce settlement before any tax liability arose; therefore, those wages should be considered her property rather than his under California law. Thus, according to them, these funds could not be seized by the IRS because they did not "belong" to Mr.Sotelo at all but instead belonged solely to Mrs.Sotelo who had no tax debt herself.