LEAVY, Circuit Judge:
In this case we are called upon to determine whether a legatee's purported renunciation of his half-interest in an estate precluded the federal government from asserting a lien against that half-interest as the result of the legatee's nonpayment of taxes. The district court held that the tax lien was valid under federal law because the renunciation failed as a matter of state law. We reverse.
FACTS AND PRIOR PROCEEDINGS
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