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BANK OF NEVADA v. UNITED STATES

No. 15541.

251 F.2d 820 (1957)

BANK OF NEVADA, Appellant, v. UNITED STATES of America, Appellee.

United States Court of Appeals Ninth Circuit.

Rehearing Denied February 7, 1958.

Attorney(s) appearing for the Case

Milton W. Keefer, B. Mahlon Brown, Las Vegas, Nev., for appellant.

Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Charles B. E. Freeman, A. F. Prescott, Sheldon I. Fink, Attys., Dept. of Justice, Washington, D. C., Franklin P. R. Rittenhouse, U. S. Atty., Las Vegas, Nev., for appellee.

Before STEPHENS, Chief Judge, and LEMMON and HAMLEY, Circuit Judges.

LEMMON, Circuit Judge.

While the Internal Revenue Code of 1954 "contains a variety of important changes in the estate and gift tax areas",1 it has left untouched the well established principle that the amount of an unpaid tax "shall be a lien in favor of the United States upon all property and rights to property"2 of the delinquent taxpayer.

No government worthy of the name will permit itself to be...

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