United States v. Union Central Life Insurance Co.

Opinion of the Court by

Mr. Justice Black, announced by Mr. Justice Frankfurter.

Robert G. Peters, Jr., and his wife, of Oakland County, Michigan, failed to pay their 1952 federal income taxes. In January 1954 an assessment for this delinquency was filed in the Internal Revenue Collector’s Office at Detroit, Michigan, at which time a lien arose “in favor of the United States upon all property” of the two delinquent taxpayers. Some 10 months after the Government’s tax lien arose, Mr. and Mrs. Peters executed a mortgage on real property they owned in Oakland County to secure an indebtedness to…