United States v. Craft

Justice Thomas, with whom Justice Stevens and Justice Scalia join,

dissenting.

The Court today allows the Internal Revenue Service (IRS) to reach proceeds from the sale of real property that did not belong to the taxpayer, respondent’s husband, Don Craft,1 because, in the Court’s view, he “possessed] individual rights in the [tenancy by the entirety] estate sufficient to constitute ‘property’ or ‘rights to property’ for the purposes of the lien” created by 26 U. S. C. § 6321. Ante, at 276. The Court does not contest that the tax liability the IRS seeks to satisfy is Mr. Craft’s alone, and does…