Decker Estate (No. 2)

Opinion by

Mr. Justice Horace Stern,

Section 3466 of the Revised Statutes, U.S.C.A. Title 31, section 191, provides for priority of payment to the United States of debts owed by an insolvent decedent’s estate. The Act of June 29, 1939, c.247, Title IY, section 401, 53 Stat. 882, U.S.C.A. Title 26, section 3672 (b) (1) provides that tax liens in favor of the United States shall not be valid with respect to a security as against any bona fide prior mortgagee, pledgee or purchaser of such security. At the argument of the present case the question presented was whether this latter act superseded,…