J. L. Enochs, District Director of Internal Revenue v. S. O. Smith and Maxine Smith

HUTCHESON, Circuit Judge:

The District Director of Internal Revenue asserts a federal tax lien under Int. Rev. Code of 1954 Section 6321 against certain properties now owned by S. 0. and Maxine Smith. The Smiths acquired the properties from Maxine’s uncle, Samuel R. Bradley, after the District Director had made assessment against Bradley, but before notice of the Government’s claim was filed for record. The court below ruled that the Smiths were “purchasers” of the properties, and thus protected from the Government’s lien by virtue of Code Section 6323(a). Unable to ascertain error in the…