BROWN, J.
We are asked to decide whether a Massachusetts liquor license is "property" or "rights to property" to which a Federal tax lien may attach. The relevant facts are as follows. In December, 1979, Harcourt and Schrouth, Inc. (Harcourt), pledged its liquor license to the plaintiff, Arrowhead Estates, Inc. (Arrowhead), as collateral for a $21,000 loan. The Boston Licensing Board approved this pledge as required by G.L.c. 138, § 23. In March, 1980, the Internal...
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