United States v. Murray

BOUDIN, Circuit Judge.

On November 21, 1988, the Internal Revenue Service made an administrative determination, called an assessment, that Michael Murray owed $105,243.06 for failure to pay over withheld income and Federal Insurance Contributions Act (“FICA”) taxes due from his company, All Air Transportation Corp. 26 U.S.C. §§ 6201-OS (1994). As of that date, a statutory lien arose in favor of the United States upon “all property and rights to property, whether real or personal,” belonging to Michael Murray. 26 U.S.C. §§ 6321-22 (1994). The central question in this case is whether that lien…