United States Ex Rel. Internal Revenue Service v. McDermott
Supreme Court of the United States
1Opinion of the Court
Justice Sc alia
delivered the opinion of the Court.
We granted certiorari to resolve the competing priorities of a federal tax lien and a private creditor’s judgment lien as to a delinquent taxpayer’s after-acquired real property.
I
On December 9, 1986, the United States assessed Mr. and Mrs. McDermott for unpaid federal taxes due for the tax years 1977 through 1981. Upon that assessment, the law created a lien in favor of the United States on all real and personal property belonging to the McDermotts, 26 U. S. C. §§6321 and 6322, including after-acquired property, Glass City Bank v. United…
2Cases cited7 opinions
- United States v. City of New BritainSupreme Court of the United States · 1954
- United States v. Pioneer American InsuranceSupreme Court of the United States · 1963
- Glass City Bank v. United StatesSupreme Court of the United States · 1945
- United States v. VermontSupreme Court of the United States · 1964
- United States v. SnyderSupreme Court of the United States · 1893
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3Cited by205 opinions
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- Roger Schlossberg, Trustee-Appellant v. Jean Barney, Debtor-AppelleeCourt of Appeals for the Fourth Circuit · 2004
- Haas v. Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1994
- Progressive Consumers Federal Credit Union v. United StatesCourt of Appeals for the First Circuit · 1996
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