BELL, Presiding Judge.
26 U. S. C. § 6321 provides for a lien on all property and rights to property belonging to a taxpayer who neglects or refuses to pay internal revenue taxes after demand. This lien is effective from the time the assessment is made (26 U. S. C. § 6322), and may be enforced by levy pursuant to 26 U. S. C. § 6331 upon all property and rights to property belonging to the taxpayer, or on which there is a lien provided, with the exception...
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