Hudson City Savings Institution v. Drossos

OPINION OF THE COURT

Weiss, J.

The sole issue in this case is whether an estate tax lien, arising upon a decedent’s death in favor of the United States of America, extends to the full value of property owned by decedent and his spouse as tenants by the entirety or is limited to decedent’s individual one-half interest.

The facts are not complicated. Decedent, Andrew Drossos, and his wife, Patricia Ann Drossos, owned real property as tenants by the entirety subject to a mortgage held by the Hudson City Savings Institution. After decedent died on May 9, 1979, the *411mortgage became delinquent and the…