Cite as: 528 U. S. 49 (1999)
Opinion of the Court
federal law, that no federal tax lien could attach to policy proceeds unavailable to the insured in his lifetime. Id., at 55-56 ("It would be anomalous to view as 'property' subject to lien proceeds never within the insured's reach to enjoy.").6
Just as "exempt status under state law does not bind the federal collector," Mitchell, 403 U. S., at 204, so federal tax law "is not struck blind by a disclaimer," United States v. Irvine, 511 U. S. 224, 240 (1994). Thus, in Mitchell, the Court held that, although a wife's renunciation of a marital interest was treated as retroactive under state law, that state-law disclaimer did not determine the wife's liability for federal tax on her share of the community income realized before the renunciation. See 403 U. S., at 204 (right to renounce does not indicate that taxpayer never had a right to property).
IV
The Eighth Circuit, with fidelity to the relevant Code provisions and our case law, determined first what rights state law accorded Drye in his mother's estate. It is beyond debate, the Court of Appeals observed, that under Arkansas
6 Compatibly, in Aquilino v. United States, 363 U. S. 509 (1960), we held that courts should look first to state law to determine " 'the nature of the legal interest' " a taxpayer has in the property the Government seeks to reach under its tax lien. Id., at 513 (quoting Morgan v. Commissioner, 309 U. S. 78, 82 (1940)). We then reaffirmed that federal law determines whether the taxpayer's interests are sufficient to constitute "property" or "rights to property" subject to the Government's lien. 363 U. S., at 513-514. We remanded in Aquilino for a determination whether the contractor-taxpayer held any beneficial interest, as opposed to "bare legal title," in the funds at issue. Id., at 515-516; see also Note, Property Subject to the Federal Tax Lien, 77 Harv. L. Rev. 1485, 1491 (1964) ("Aquilino supports the view that the Court has chosen to apply a federal test of classification, for the contractor concededly had legal title to the funds and yet in remanding the Court indicated that this state-created incident of ownership was not a sufficient 'right to property' in the contract proceeds to allow the tax lien to attach. In this sense Aquilino follows Bess in requiring that the taxpayer must have a beneficial interest in any property subject to the lien." (footnote omitted)).
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