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State Law Disclaimer Did Not Prevent the Attachment of Federal Tax Liens to Inherited Property: Drye Family 1995 Trust v. United States

In Drye Family 1995 Trust v. United States, the Eighth Circuit held that an individual's disclaimer of an inheritance for state law purposes did not prevent the attachment of pre-existing federal tax liens to the inheritance under section 6321. There has been some controversy over the effect of disclaimers on federal tax liens, as the Second, Fifth, and Ninth Circuits...

Andrew J. Lawrence

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