United States v. Taylor

MEMORANDUM OPINION AND ORDER

GEORGE B. HARRIS, Chief Judge.

This case presents two novel problems in the law of federal tax liens. The first concerns whether such a lien can attach to a life interest in a trust for support, and how, if the lien does attach, it may be effectively foreclosed. The second concerns the effectiveness, as against a federal tax lien, of a “forfeiture” clause which provides that a beneficiary’s interest in the trust shall terminate if it becomes payable to the federal government. The facts giving rise to these problems are not in dispute and the matter has been…