United States v. Avila

*231OPINION OF THE COURT

GREENBERG, Circuit Judge.

In this case we must determine whether the government’s tax lien in real property is limited to a taxpayer’s equity when he conveyed the property subject to the lien or whether the lien also attaches to the appreciation in the value of the property after the conveyance. Since nothing in the relevant statutes suggests that the government lien should be limited to the value of the taxpayer’s equity in the property at the time of the conveyance and since the conveyance cannot affect the lien, we will reverse the district court’s order based on its…