Iowa Fair Plan v. United States, Internal Revenue Department

I cannot agree with the conclusions reached by the majority and respectfully dissent.

I. The issue on which this appeal rests is the nature and character of the insurance proceeds as property. If the proceeds are property acquired after the attachment of the liens (that is, on the date of the fire which destroyed the building) the federal law primes the simultaneously attached state lien. United States v. New Britain, 347 U.S. 81, 74 S.Ct. 367, 98 L.Ed. 520 (1954). If the liens survive the conversion of form of the property, the date of the attachment of the liens to the original property…