Bolling v. Samples

Bell, Presiding Judge.

26 U. S. C. § 6321 provides for a lien on all property and rights to property belonging to a taxpayer who neglects or refuses to pay internal revenue taxes after demand. This lien is effective from the time the assessment is made (26 U. S. C. § 6322), and may be enforced by levy pursuant to 26 U. S. C. § 6331 upon all property and rights to property belonging to the taxpayer, or on which there is a lien provided, with the exception of specific exemptions provided by 26 U. S. C. § 6334, which is not applicable here. 26 U. S. C. § 6332 (a) provides: “Any person in…