Legal Opinion

United States v. Estate of Donnelly

Supreme Court of the United States

Decided March 23, 1970No. 104PublishedCited by 116 opinions

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

  1. Chicot County Drainage District v. Baxter State BankSupreme Court of the United States · 1940
  2. Simpson v. Union Oil Co. of Cal.Supreme Court of the United States · 1964
  3. United States v. Union Central Life Insurance Co.Supreme Court of the United States · 1961
  4. Youngblood v. United StatesCourt of Appeals for the Sixth Circuit · 1944
  5. 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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3Cited by116 opinions

  1. James B. Beam Distilling Co. v. GeorgiaSupreme Court of the United States · 1991
  2. Lemon v. KurtzmanSupreme Court of the United States · 1973
  3. American Trucking Assns., Inc. v. SmithSupreme Court of the United States · 1990
  4. Reynoldsville Casket Co. v. HydeSupreme Court of the United States · 1995
  5. United States v. City of Tacoma, WashingtonCourt of Appeals for the Ninth Circuit · 2003

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