Gordon White Construction Company, Inc., and Henry A. Stikes, Sr., Trustee v. Southland Investment Co., United States of America

DYER, Circuit Judge:

In this action by the trustee in bankruptcy to allow him to convey certain real and personal property free of liens and encumbrances, the district court con strued Title 33, Section 9 of the Alabama Code as permitting the filing of federal tax liens in more than one local office, thus concluding that this statute did not comply with the “one office” requirement of Int.Rev.Code, § 6323(f). The government, contending that it held a tax lien valid as against the trustee, appeals. We reverse.

Int.Rev.Code, § 6321, gives the United States a lien on all property, real and…