have improperly conducted their affairs. It has been the whole course of our law to break down barriers against calling corporations to account in all states where they may do wrong in doing business. Neirbo Co. v. Bethlehem Shipbuilding Corp., 308 U. S. 165. Lumbermens qualified in New York to carry on its regular insurance business. It sold plaintiff a policy that shares in the profits of that business and it should require a showing much stronger than any here made to require this policyholder to go away from home for relief. Petitioner, on behalf of Lumbermens, seeks recovery for excessive payments and services by Lumbermens to those who dominate the company, and for sales of company assets to those persons at inadequate prices. Petitioner must prove these allegations. None are now denied by defendant. That petitioner's success will result in "monetary damage" to Lumbermens seems impossible. Petitioner's success will enrich Lumbermens at the expense of those who are alleged to have mulcted it of large sums. Petitioner speaks for the whole membership and all policyholders of Lumbermens. From this record, we do not see that an adequate basis of fact has been laid by the respondent's affidavits to overcome the right of petitioner to pursue his remedies in the District Court for the Eastern District of New York MR. JUSTICE BURTON joins in this dissent. Counsel for Parties. UNITED STATES DEPARTMENT OF AGRICULTURE, EMERGENCY CROP AND FEED LOANS v. REMUND, ADMINISTRATOR. CERTIORARI TO THE SUPREME COURT OF SOUTH DAKOTA. No. 417. Argued February 5, 1947-Decided March 17, 1947. 1. Under R. S. § 3466, which provides that "whenever the estate of any deceased debtor . . . is insufficient to pay all the debts due from the deceased, the debts due to the United States shall be first satisfied," a claim asserted in a state probate proceeding by an official of the Farm Credit Administration for and on behalf of the United States, on account of unpaid emergency feed and crop loans made pursuant to the Acts of February 23 and June 19, 1934, is entitled to priority. Pp. 541-545. 2. A debt owed the Farm Credit Administration is a debt owed the United States within the meaning of R. S. § 3466. Pp. 541-542. 3. The priority given by R. S. § 3466 to debts due to the United States is unaffected by the fact that a claim based upon such a debt is filed in the name of an agency of the United States or an authorized officer of such an agency. Pp. 542-543. 4. There is no irreconcilable conflict between making emergency loans to distressed farmers and granting priority to the collection of such loans pursuant to R. S. § 3466. Pp. 543–545. 5. Only the plainest inconsistency would warrant an implied exception to the priority established by R. S. § 3466. Pp. 544-545. 70 S. D., 23 N. W. 2d 281, reversed. A claim by an official of the Farm Credit Administration for and on behalf of the United States against the estate of an insolvent decedent in a state probate proceeding was denied priority under R. S. § 3466 by a probate court. The State Supreme Court affirmed. 70 S. D. —, 23 N. W. 2d 281. This Court granted certiorari. 329 U.S. 703. Reversed, p. 545. Paul A. Sweeney argued the cause for petitioner. With him on the brief were Acting Solicitor General Washing Opinion of the Court. 330 U.S. ton, Assistant Attorney General Sonnett, Melvin Richter and Philip Elman. Dwight Campbell submitted on brief for the respondent. Opinion of the Court by MR. JUSTICE MURPHY, announced by MR. JUSTICE RUTLEDGE. We are faced here with the problem of whether, in a state probate proceeding, a claim asserted by the Farm Credit Administration through certain of its officials for and on behalf of the United States is entitled to priority under § 3466 of the Revised Statutes, 31 U. S. C. § 191. The Governor of the Farm Credit Administration, pursuant to the Acts of February 23, 1934,1 and June 19, 1934,2 extended emergency feed and crop loans totalling $370.00 to Wilhelm Buttke, a South Dakota farmer. Most of these loans remained unpaid. On December 26, 1941, Buttke died intestate, leaving an estate insufficient to pay all of his debts. Respondent was appointed administrator of the estate. On March 2, 1942, an authorized agent of the Governor of the Farm Credit Administration filed in the County Court of Roberts County, South Dakota, a claim against the estate for $523.80, the amount of the unpaid indebtedness plus interest. This claim was made "for and on behalf of the United States of America" and a priority therefor on behalf of the United States was asserted under § 3466 of the Revised Statutes. The County Court denied preference to this claim. But it did allow the claim in the amount of $79.53, which represented the pro rata share of a common creditor's claim. This decision was affirmed by the Circuit Court of the Fifth Judicial Circuit of South Dakota and by the Supreme Court of South Dakota. 70 S. D., 23 N. W. 1 48 Stat. 354. 2 48 Stat. 1021, 1056. 539 Opinion of the Court. 2d 281. The latter court felt that the Acts of February 23, 1934, and June 19, 1934, created an exception to § 3466 and that the claimed priority should accordingly be refused on the authority of United States v. Guaranty Trust Co., 280 U. S. 478. We granted certiorari because of the important problems thereby raised. The relevant portion of § 3466 of the Revised Statutes provides that ". whenever the estate of any deceased debtor, in the hands of the executors or administrators, is insufficient to pay all the debts due from the deceased, the debts due to the United States shall be first satisfied .. Initially, it is suggested that § 3466 is inapplicable since the claim in issue is not a debt due to the United States. The claim grows out of the seven notes executed by the deceased to "the Governor of the Farm Credit Administration, or order, at Washington, D. C." These notes stated that they were "given as evidence of a loan made by the Governor of the Farm Credit Administration." On the premise that the Farm Credit Administration is an entity separate and distinct from the United States Government, the argument is made that obligations due the Farm Credit Administration fall outside the priority established by § 3466. We cannot agree. The Farm Credit Administration is plainly one of the many administrative units of the United States Government, established to carry out the functions delegated to it by Congress. It bears none of the features of a government corporation with a legal entity separate from that of the United States, whatever difference that might make as to the application of § 3466. Cf. Sloan Shipyards Corp. v. United States Fleet Corp., 258 U. S. 549. It had its inception in 1933 as an independent agency, assuming the functions of the Federal Farm Board and the Federal Farm Loan Board. Executive Order No. 6084. In 1939, Opinion of the Court. 330 U.S. it was transferred to the Department of Agriculture and placed under the general supervision and direction of the Secretary of Agriculture. Reorganization Plan No. 1, § 401 (a), 53 Stat. 1429, 4 Fed. Reg. 2730. Its functions, personnel and property were then consolidated in 1942 with those of certain other agencies to form the Food Production Administration of the Department of Agriculture. Executive Order No. 9280, 7 Fed. Reg. 10179. At no time has the Farm Credit Administration been other than an unincorporated agency of the United States Government, administering and lending funds appropriated by Congress out of the United States Treasury and returning the money to the Treasury upon repayment. In short, it is an integral part of the governmental mechanism. And the use of a name other than that of the United States cannot change that fact. United States v. Fontenot, 33 F. Supp. 629; In re Wilson, 23 F. Supp. 236; Federal Reserve Bank of Dallas v. Smylie, (Tex. Civ. App.) 134 S. W. 2d 838; Helms v. Emergency Crop & Seed Loan Office, 216 N. C. 581, 5 S. E. 2d 822. See also North Dakota-Montana Wheat Growers' Assn. v. United States, 66 F. 2d 573. Hence any debt owed the Farm Credit Administration is a debt owed the United States within the meaning of § 3466. Moreover, the priority given by § 3466 to a debt due to the United States is unaffected by the fact that a claim based upon that debt is filed in the name of an agency of the United States or an authorized officer of such an agency. It is enough that there is an obligation owed the United States. Whether the claim is filed in the name of the United States or in the name of an officer or agency is immaterial; in the latter instance, the claim is necessarily filed on behalf of the United States and the legal effect is the same as if it had been filed in that name. Nothing in the language or policy of § 3466 justifies any other conclusion. It follows that the method of filing in |