Planters National Bank & Trust Co. v. South Carolina Insurance

It is provided in 26 U.S.C.A., § 6321, “If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount * * shall be a lien in favor of the United States upon all property and rights to property, whether real or personal, belonging to such person.”

It is further provided in 26 U.S.C.A., § 6322: “Unless another date is specifically fixed by law, the lien imposed by section 6321 shall arise at the time the assessment is made and shall continue until the liability for the amount so assessed is satisfied or becomes unenforceable by reason of lapse of time”

Likewise,…