United States v. Estate of Donnelly
Supreme Court of the United States
1Opinion of the CourtJustice Marshall
In 1950, a tax liability of approximately $26,000 was assessed against the taxpayer Donnelly, a resident of Michigan. Upon assessment, a statutory lien was created in favor of the United States “upon all property and rights to property, whether real or personal” belonging to the taxpayer. Internal Revenue Code of 1939, § 3670. Under § 3672 of the 1939 Code, such a lien could become effective against subsequent purchasers of Donnelly’s property in either of two ways: (1) by filing notice of the lien in the state office in which filing of such notice was authorized by state law; or (2) if…
2Cases cited7 opinions
- Chicot County Drainage District v. Baxter State BankSupreme Court of the United States · 1940
- Simpson v. Union Oil Co. of Cal.Supreme Court of the United States · 1964
- United States v. Union Central Life Insurance Co.Supreme Court of the United States · 1961
- Youngblood v. United StatesCourt of Appeals for the Sixth Circuit · 1944
- United States v. Estate of Thomas S. Donnelly, Sr., Oscar A. Carlson and Genevieve S. CarlsonCourt of Appeals for the Sixth Circuit · 1969
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- Reynoldsville Casket Co. v. HydeSupreme Court of the United States · 1995
- United States v. City of Tacoma, WashingtonCourt of Appeals for the Ninth Circuit · 2003
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