Commissioner of Internal Revenue v. Plestcheeff

The construction given by the Board of Tax Appeals to § 11265 of the Washington code was based on the assumed authority of State v. Snohomish County, 71 Wash. 320, 128 P. 667. However, the state court there held only that real property in private ownership on March 1, but in public ownership when the taxes for the year are levied, cannot be subjected to the payment of taxes for that year. The Snohomish County Case is not properly to be taken as authority for the view that the Hen of a tax, under the state law, becomes effective only upon the making of a levy.

It is clear, as the majority…