United States v. Pioneer American Insurance

The United States has sought review of a decision of the Supreme Court of Arkansas subordinating the federal tax lien (26 U. S. C. § 6321) to a lien for attorney’s fees included in an antecedent mortgage contract. 235 Ark. 267, 357 S. W. 2d 653: Because of conflict between the Arkansas decision and United States v. Bond, 279 F. 2d 837 (C. A. 4th Cir.); In re New Haven Clock & Watch Co., 253 F. 2d 577 (C. A. 2d Cir.), we granted certiorari. 371 U. S. 909.

When the taxpayers in 1958 acquired their -interest in the parcel of real estate involved hete, they assumed liability on a note and the deed…