In the 1931 case Van Huffel v. Harkelrode, Treasure, the U.S. Supreme Court ruled that a tax lien on real estate held by a federal court in bankruptcy proceedings is not extinguished unless there is an explicit statute to that effect or clear evidence of congressional intent. The case involved Mrs. Van Huffel who had purchased property at a sheriff's sale which was subject to federal tax liens for unpaid taxes owed by previous owners (Harklerode and Treasure). After acquiring the property, she sought to have these liens removed arguing they were discharged during bankruptcy proceedings prior her purchase of the property. The lower courts agreed with Mrs. Van Huffel but upon appeal, the Supreme Court reversed this decision stating that nothing in Bankruptcy Act suggested Congress intended for it to discharge pre-existing tax liens on real estate under such circumstances.

In the dissenting opinion for Van Huffel v. Harkelrode, it was argued that the majority's decision to allow a tax lien on property without providing notice to the owner violated due process rights under the Fourteenth Amendment. The dissenting justices believed that even though there may be practical difficulties in identifying and notifying all potential claimants of a tax sale, these challenges did not justify denying individuals their constitutional right to due process. They contended that any law which allows for deprivation of property without proper notification is inherently unfair and unconstitutional. Furthermore, they disagreed with the majority’s view that ignorance or negligence on part of property owners could excuse such lack of notice. In essence, they held firm belief in upholding individual rights over administrative convenience or efficiency.