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UNITED STATES v. CRAFT

No. 00-1831.

535 U.S. 274 (2002)

122 S.Ct. 1414

152 L.Ed.2d 437

UNITED STATES v. CRAFT

Supreme Court of United States.

Decided April 17, 2002.

Attorney(s) appearing for the Case

Kent L. Jones argued the cause for the United States. With him on the briefs were Solicitor General Olson, Assistant Attorney General O'Connor, Deputy Solicitor General Wallace, David English Carmack, and Joan I. Oppenheimer.

Jeffrey S. Sutton argued the cause for respondent. With him on the briefs were Chad A. Readler, Jeffrey A. Moyer, and Michael Dubetz, Jr.

Justice O'Connor, delivered the opinion of the Court.

This case raises the question whether a tenant by the entirety possesses "property" or "rights to property" to which a federal tax lien may attach. 26 U. S. C. § 6321. Relying on the state law fiction that a tenant by the entirety has no separate interest in entireties property, the United States Court of Appeals for the Sixth Circuit held that such property is exempt from the tax lien. We conclude that, despite...

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