Aquilino v. United States (1959)
- Docket
- 1
- Decided
- 1959-01-01
- Category
- General
Summary
Question: Does the statutorily-created trust create “property” or “rights to property” under federal tax law? Conclusion: In a 7-2 decision Justice Earl Warren wrote the majority opinion vacating the judgment below. The Supreme Court held that state law controlled the answer to the question presented, while federal law controlled the priority of the competing liens. The Court remanded the case to the New York Court of Appeals to determine the nature of the property rights under state law. Justice John M. Harlan wrote a dissent, stating that the majority’s decision was inconsistent with prior case law. Justice Hugo L Black joined in the dissent.