RIVES, Circuit Judge:
This proceeding under Chapter X of the Bankruptcy Act, 11 U.S.C.A. §§ 501-676, for the reorganization of TMT Trailer Ferry, Inc., has been pending for more than six years, and has been before this Court on three prior occasions.1 The United States is now appealing from an order which denies priority to its nontax claims.2 The United States also appeals from subsequent orders of the district court amending, confirming and authorizing consummation of a plan of reorganization which fails to recognize the priority of the Government’s nontax claims.3
The basic issue presented by the appeals is whether R.S. § 3466, 31 U.S.C.A. § 191,4 is operative to give all debts due to the United States priority in this Chapter X corporate reorganization proceeding. The district court held that the only debts due the United States granted priority in Chapter X reorganization proceedings are those for taxes and customs duties, and that the controlling statute is section 199 of the Bankruptcy [114]*114Act, 11 U.S.C.A. § 599.5 Two of the nontax claims 6 were held not entitled to priority in any event because, according to the district court, “at the time the petition herein was filed they were not owed to the United States.”
Any priority allowed to claims of the United States must be founded upon statute. As was said by Mr. Justice Story in the early case of United States v. State Bank of North Carolina, 1832, 31 U.S. (6 Pet.) 29, 35, 8 L.Ed. 308:
“The right of priority of payment of debts due to the government, is a perogative of the crown well known to the common law. It is founded not so much upon any personal advantage to the sovereign, as upon motives of public policy, in order to secure an adequate revenue to sustain the public burdens, and discharge the public debts. The claim of the United States, however, does not stand upon any sovereign perog-ative, but is exclusively founded upon the actual provisions of their own statutes. The same policy which governed in the case of the royal perogative, may be clearly traced in these statutes; and as that policy has mainly a reference to the public good, there is no reason for giving to them a strict and narrow interpretation. Like all other statutes of this nature, they ought to receive a fair and reasonable interpretation, according to the just import of their terms.”
Mr. Justice Story then referred to the duty-collection act of August 4, 1790, ch. 62, see. 45, to the Act of March 3, 1797, 1 Stat. 515, and to the Act of March 2, 1799, 1 Stat. 676. The pertinent provisions of the latter two Acts have remained substantially unchanged throughout nearly the entire history of our Nation, and are now embodied in R.S. § 3466, quoted in footnote 4, supra. As was more fully developed in an even earlier case, that priority extends to debts of all kinds, equitable as well as legal, and even to endorsements of a bill of exchange of which the Government is a holder. United States v. Fisher, 1805, 2 Cranch (6 U.S.) 358, 383-397, 2 L.Ed. 304.
Acts on the subject of bankruptcy were enacted in 1800 (2 Stat. 19), which Act was repealed in 1803; in 1841 (5 Stat. 440, 614), which Act was repealed in 1843; and in 1867 (14 Stat. 530, R.S. § 5101), which Act was repealed in 1878.
The 1800 Act provided, in sec. 62 thereof, that:
“[N]othing contained in this law shall, in any manner, effect the right of preference to prior satisfaction of debts due the United States as secured or provided by any law heretofore passed.”
The 1841 Act provided, in section 5 thereof, that all creditors should share in the bankrupt’s estate pro rata, without preference or priority:
“except only for debts due by such bankruptcy to the United States.”
[115]*115The 1867 Act carried forward the priority in section 28 thereof by providing that:
“the following claims shall be entitled to priority or preference, and to be paid in full in the following order:—
“ ‘First. (Administrative expenses)
“ ‘Second. All debts due to the United States and all taxes and assessments under the laws thereof.’ ”
While these Acts were in effect there was, therefore, no question but that non-tax claims of the United States had priority in bankruptcy proceedings. From the time the 1867 Act was repealed in 1878 until the present Bankruptcy Act was enacted in 1898, we had no federal bankruptcy laws.
The Bankruptcy Act of 1898, as originally enacted, was construed by the Supreme Court to give priority only to “all taxes, legally due * * * to the United States,” and not to afford priority for ordinary debts due to the United States. Davis v. Pringle, 1924, 268 U.S. 315, 317-319, 45 S.Ct. 549, 550, 69 L.Ed. 974.
By the amendment of 1926 (44 Stat. at L. 662, chap. 406), Congress repealed the effect of that decision by adding the words now in section 64, sub. a(5) [11 U.S.C.A. § 104] which specifically include the United States within the definition of the word “persons” to whom a priority status was given. So at the present time, by reason of the provisions of section 64, sub. a(5) as amended in 1926, all claims of the United States, whether tax or non-tax, are given priority in conventional bankruptcy proceedings under Chapters I to VII of the Act, just as they were under the 1867 Act until it was repealed.
This Chapter X reorganization is, of course, not a conventional bankruptcy. Section 64 (11 U.S.C.A. § 104) is expressly made inapplicable to Chapter X proceedings by section 102 of Chapter X (11 U.S.C.A. § 502). Section 64 being thus excluded, the appellees argue that Davis v. Pringle, supra, teaches that R.S. § 3466 is not applicable to bankruptcy proceedings in the absence of a provision to that effect in the Bankruptcy Act, or otherwise stated, that we must look solely to the Bankruptcy Act for any priority status that must be recognized.7 That is true, however, only when the terms of the Bankruptcy Act evidence an intention to cover all matters of priorities or when they are inconsistent with previous statutes such as R.S. § 3466. Davis v. Pringle, supra; Guaranty Title and Trust Co. v. Title Guaranty and S. Co., 1911, 224 U.S. 152, 32 S.Ct. 457, 56 L.Ed. 706; New York v. Saper, 1949, 336 U.S. 328, 340, n. 18, 69 S.Ct. 554, 93 L.Ed. 710.
Chapter X proceedings resemble equity receiverships more closely than they resemble conventional bankruptcy proceedings. As Mr. Justice Cardozo said in Lowden v. Northwestern National Bank & Trust Co., 1936, 298 U.S. 160, 163, 56 S.Ct. 696, 698, 80 L.Ed. 1114:
“A proceeding to reorganize is not a bankruptcy, though an amendment to the bankruptcy act creates and regulates the remedy.”
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RIVES, Circuit Judge:
This proceeding under Chapter X of the Bankruptcy Act, 11 U.S.C.A. §§ 501-676, for the reorganization of TMT Trailer Ferry, Inc., has been pending for more than six years, and has been before this Court on three prior occasions.1 The United States is now appealing from an order which denies priority to its nontax claims.2 The United States also appeals from subsequent orders of the district court amending, confirming and authorizing consummation of a plan of reorganization which fails to recognize the priority of the Government’s nontax claims.3
The basic issue presented by the appeals is whether R.S. § 3466, 31 U.S.C.A. § 191,4 is operative to give all debts due to the United States priority in this Chapter X corporate reorganization proceeding. The district court held that the only debts due the United States granted priority in Chapter X reorganization proceedings are those for taxes and customs duties, and that the controlling statute is section 199 of the Bankruptcy [114]*114Act, 11 U.S.C.A. § 599.5 Two of the nontax claims 6 were held not entitled to priority in any event because, according to the district court, “at the time the petition herein was filed they were not owed to the United States.”
Any priority allowed to claims of the United States must be founded upon statute. As was said by Mr. Justice Story in the early case of United States v. State Bank of North Carolina, 1832, 31 U.S. (6 Pet.) 29, 35, 8 L.Ed. 308:
“The right of priority of payment of debts due to the government, is a perogative of the crown well known to the common law. It is founded not so much upon any personal advantage to the sovereign, as upon motives of public policy, in order to secure an adequate revenue to sustain the public burdens, and discharge the public debts. The claim of the United States, however, does not stand upon any sovereign perog-ative, but is exclusively founded upon the actual provisions of their own statutes. The same policy which governed in the case of the royal perogative, may be clearly traced in these statutes; and as that policy has mainly a reference to the public good, there is no reason for giving to them a strict and narrow interpretation. Like all other statutes of this nature, they ought to receive a fair and reasonable interpretation, according to the just import of their terms.”
Mr. Justice Story then referred to the duty-collection act of August 4, 1790, ch. 62, see. 45, to the Act of March 3, 1797, 1 Stat. 515, and to the Act of March 2, 1799, 1 Stat. 676. The pertinent provisions of the latter two Acts have remained substantially unchanged throughout nearly the entire history of our Nation, and are now embodied in R.S. § 3466, quoted in footnote 4, supra. As was more fully developed in an even earlier case, that priority extends to debts of all kinds, equitable as well as legal, and even to endorsements of a bill of exchange of which the Government is a holder. United States v. Fisher, 1805, 2 Cranch (6 U.S.) 358, 383-397, 2 L.Ed. 304.
Acts on the subject of bankruptcy were enacted in 1800 (2 Stat. 19), which Act was repealed in 1803; in 1841 (5 Stat. 440, 614), which Act was repealed in 1843; and in 1867 (14 Stat. 530, R.S. § 5101), which Act was repealed in 1878.
The 1800 Act provided, in sec. 62 thereof, that:
“[N]othing contained in this law shall, in any manner, effect the right of preference to prior satisfaction of debts due the United States as secured or provided by any law heretofore passed.”
The 1841 Act provided, in section 5 thereof, that all creditors should share in the bankrupt’s estate pro rata, without preference or priority:
“except only for debts due by such bankruptcy to the United States.”
[115]*115The 1867 Act carried forward the priority in section 28 thereof by providing that:
“the following claims shall be entitled to priority or preference, and to be paid in full in the following order:—
“ ‘First. (Administrative expenses)
“ ‘Second. All debts due to the United States and all taxes and assessments under the laws thereof.’ ”
While these Acts were in effect there was, therefore, no question but that non-tax claims of the United States had priority in bankruptcy proceedings. From the time the 1867 Act was repealed in 1878 until the present Bankruptcy Act was enacted in 1898, we had no federal bankruptcy laws.
The Bankruptcy Act of 1898, as originally enacted, was construed by the Supreme Court to give priority only to “all taxes, legally due * * * to the United States,” and not to afford priority for ordinary debts due to the United States. Davis v. Pringle, 1924, 268 U.S. 315, 317-319, 45 S.Ct. 549, 550, 69 L.Ed. 974.
By the amendment of 1926 (44 Stat. at L. 662, chap. 406), Congress repealed the effect of that decision by adding the words now in section 64, sub. a(5) [11 U.S.C.A. § 104] which specifically include the United States within the definition of the word “persons” to whom a priority status was given. So at the present time, by reason of the provisions of section 64, sub. a(5) as amended in 1926, all claims of the United States, whether tax or non-tax, are given priority in conventional bankruptcy proceedings under Chapters I to VII of the Act, just as they were under the 1867 Act until it was repealed.
This Chapter X reorganization is, of course, not a conventional bankruptcy. Section 64 (11 U.S.C.A. § 104) is expressly made inapplicable to Chapter X proceedings by section 102 of Chapter X (11 U.S.C.A. § 502). Section 64 being thus excluded, the appellees argue that Davis v. Pringle, supra, teaches that R.S. § 3466 is not applicable to bankruptcy proceedings in the absence of a provision to that effect in the Bankruptcy Act, or otherwise stated, that we must look solely to the Bankruptcy Act for any priority status that must be recognized.7 That is true, however, only when the terms of the Bankruptcy Act evidence an intention to cover all matters of priorities or when they are inconsistent with previous statutes such as R.S. § 3466. Davis v. Pringle, supra; Guaranty Title and Trust Co. v. Title Guaranty and S. Co., 1911, 224 U.S. 152, 32 S.Ct. 457, 56 L.Ed. 706; New York v. Saper, 1949, 336 U.S. 328, 340, n. 18, 69 S.Ct. 554, 93 L.Ed. 710.
Chapter X proceedings resemble equity receiverships more closely than they resemble conventional bankruptcy proceedings. As Mr. Justice Cardozo said in Lowden v. Northwestern National Bank & Trust Co., 1936, 298 U.S. 160, 163, 56 S.Ct. 696, 698, 80 L.Ed. 1114:
“A proceeding to reorganize is not a bankruptcy, though an amendment to the bankruptcy act creates and regulates the remedy.”
The legislative history of Chapter X indicates the reasons for not adopting the strict priority provisions of section 64, and that the priorities used in equity receiverships would be preferable. Mr. Gerdes, one of the draftsmen of Chapter X, testified in the hearings before the Senate Judiciary Committee on H.R. 8046, 75th Cong., 2d sess. 1937, 1938, p. 79:
“Section 64 of the general bankruptcy act, for example, provides for a fixed priority in the payment of claims. This section deals solely with unsecured claims, only unse[116]*116cured claims being affected by bankruptcy. To apply it in corporate reorganizations — where secured as well as unsecured claims are dealt with —would cause great confusion. To make it clear that Section 64 does not apply, we propose this amendment which expressly provides that 64 shall not be applicable to chapter X. The priorities under chapter X would therefore be those used in equity receiverships. That is the present practice under 77B, which expressly provides that section 64 shall not be applicable. When we adopt the same provision here we merely adopt the practice which is already in existence under section 77B.” (Emphasis supplied.)
Section 115 of Chapter X, 11 U.S.C.A. § 515,8 confers on the reorganization court all the powers which a court of the United States would have if it had appointed a receiver in equity of the property of the debtor on the ground of insolvency or inability to meet its debts as they mature. It thus clearly appears that the terms of Chapter X were not intended to cover all matters of priori-ies.9
Nor do we think that section 199 (quoted supra in n. 5) is inconsistent with R.S. § 3466. Section 199 is applicable in the reorganization of solvent as well as insolvent corporations. It requires the consent of the Secretary of the Treasury to the confirmation of any plan of reorganization which does not provide for the payment of claims of the United States for taxes. This provision first appeared in the Act of August 29, 1935, 49 Stat. 965, 966, which amended former section 1TB of the Bankruptcy Act to give a first priority to tax claims of the United States. Its legislative history shows that its purpose was to insure full payment of taxes and customs claims in every reorganization proceeding, including those involving solvent corporations where R.S. § 3466 would not apply. See Senate Report No. 1386, 74 Cong., 1st sess.
In addition to section 199, the appellees refer to other provisions of Chapter X which they contend are inconsistent with R.S. § 3466.10 Those provisions make no reference to the United States, The proposition is established, “that the United States as a sovereign is not bound by the general language of a statute, and is not bound by the provisions of an in-solvency law, unless specifically mention-ted therein.” Guarantee Co. v. Title Guaranty Co., 1912, 224 U.S. 152,155, 32 S.Ct. 457, 458, 56 L.Ed. 706.
[117]*117As has been noted, it was said as early as 1832 that R.S. § 3466 should be given a liberal construction. United States v. State Bank of North Carolina, supra, 31 U.S. (6 Pet.) at 35. In more recent years the Supreme Court has repeatedly said that, “There exists now the same reasons for a liberal construction of the priority act as when the rule was laid down.” Bramwell v. United States Fidelity Co., 1926, 269 U.S. 483, 487, 46 S.Ct. 176, 177, 70 L.Ed. 368, followed in United States v. Emory, 1941, 314 U.S. 423, 426, 428-430, 62 S.Ct. 317, 86 L.Ed. 315. Repeatedly also the Supreme Court has announced the principle that, “Only the plainest inconsistency would warrant our finding an implied exception to the operation of so clear a command as that of § 3466.” United States v. Emory, supra, 314 U.S. at 433, 62 S.Ct. at 322, followed in United States Dept. of Agriculture, etc. v. Remund, 1947, 330 U.S. 539, 545, 67 S.Ct. 891, 91 L.Ed. 1082. We find no such inconsistency between the purpose and provisions of Chapter X of the Bankruptcy Act and section 3466.11
The district court further held that the first two claims listed in footnote 2, supra, that is Maritime Administration $696,494.19 and Small Business Administration $124,608.59, are not entitled to priority in any event because at the time the involuntary petition was filed they were not owed to the United States.12
The involuntary petition was filed on June 27, 1957. TMT first moved to dismiss that petition, and when the district court refused to dismiss, TMT denied insolvency or commission of an act of bankruptcy. It was not until November 15, 1957, that TMT filed a petition consenting to reorganization, confessing insolvency and praying for the appointment of trustees. Up to that date no receiver had been sought or appointed and TMT had continued business as usual. On November 18, 1957 the district court approved a petition for reorganization and appointed trustees.
At sometime prior to November 15, 1957, the United States had unquestionably become the owner of both claims.13 The Government insists that as early as the date of the filing of the involuntary petition, the claims of the Maritime Administration and the Small Business Administration were provable priority claims. We find it unnecessary to pass upon that insistence, because if the two claims were not then provable priority claims of the United States they became such after the filing of the involuntary petition and before the appointment of the trustees, and thus come clearly within the terms of section 201 of the Bankruptcy Act, 52 Stat. 840, 893, 11 U.S.C.A. § 601.
Ҥ 601. Provability of claims arising after petition
“All claims arising after the filing of a petition under this chapter and before the qualification of a receiver or trustee or before the petition is approved and the debtor continued in possession, whichever first occurs, shall be provable.”
As said in 6 Collier on Bankruptcy, 14th ed., para. 9.11, p. 2836, “This provision (referring to sec. 201) places the claims encompassed thereby on the same footing for purposes of classifica[118]*118tion as claims arising prior to the filing of the petition.” 14
We hold, therefore, that all of the claims of the United States listed in footnote 2, supra, are entitled to the priority provided by R.S. § 3466. That holding necessitates a reversal of each of the orders from which the several appeals are prosecuted, and it is not necessary to rule upon the Government’s further insistence that after its appeal from the order denying priority to its nontax claims was pending before this Court, the district court had no jurisdiction to enter orders amending, confirming and authorizing consummation of a reorganization plan which denied priority to the nontax claims. The orders in Nos. 20400, 20563 and 20659 are reversed and the causes remanded for further proceedings consistent with this opinion.
Reversed and remanded.