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NOTES 951 Tax Lawyer, Vol. 53, No. 4 NOTE DISCLAIMER OF INTESTATE’S ESTATE UNDER ARKANSAS LAW CANNOT PREVENT ATTACHMENT OF FEDERAL TAX LIEN: DRYE V. UNITED STATES In Drye v. United States,1 the Supreme Court affirmed the Eighth Circuit’s decision that a taxpayer’s right to disclaim an interest in an intestate’s estate under state law does not prevent the attachment of federal tax liens.2 The Court’s decision to grant certiorari stemmed from a split among the Second, Fifth, Eighth, and Ninth...