United States v. Erick R. Rasmuson and Oscar Rasmuson, D/B/A Rasmuson Bros.

JOHNSEN, Circuit Judge.

The Government has appealed from a holding of the District Court, that a Notice of Tax Lien, against Louis Stock-well, filed by the Collector of Internal Revenue, in the office of the Register of Deeds of Hennepin County, Minnesota, under amended § 3672(a) (1) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 3672(a) (1), was invalid as against ap-pellees, judgment creditors of Stockwell.

Sections 3670 and 3671 of the 1939 Code, 26 U.S.C.A. §§ 3670, 3671 give the Government a lien upon all property of a taxpayer for any taxes not paid on demand, from the time that the…