United States v. Delaware Trust Co.

LAYTON, District Judge.

The question- presented for decision here is whether notice of a tax lien filed in the State of the taxpayer’s residence was effective to make such tax lien valid as against an assignee of taxpayer’s interest as beneficiary of a trust consisting of real property located in another state where notice of the lien was not filed.

The Commissioner of Internal Revenue assessed income taxes against the defendant Charles P. Gooding, as follows :

Assessment List

Year Received Amount

1948 July 31, 1950 $971.26

1949 August 14, 1950 555.10

1950 July 16, 1951 40.17

Notices of liens for the…