United States v. James A. Overman, Marie T. Overman, Circle J. Inc., a Corporation

HUFSTEDLER, Circuit Judge.

This interlocutory appeal raises novel questions about the creation and enforcement of federal tax liens levied on Washington community property to secure payment of a husband’s premarital income tax liability.

In 1954 the Internal Revenue Service levied deficiency assessments against the taxpayer in respect of his income taxes for the years 1946 and 1947. The taxpayer married Marie Overman in 1948. When the taxpayer failed to meet the deficiency demand, a notice of federal tax liens was filed with the proper Washington state officials. The Government sued in 1960 to…