Hugo Black,
United States v. Speers — Dissent
“ Section 6323 of the 1954 Internal Revenue Code provides that an unfiled tax lien is not 'valid as against any mortgagee, pledgee, purchaser, or judgment creditor * * *.' The Court here holds that a bankruptcy trustee must be treated as if he were a 'judgment creditor' thereby reducing government tax claims to the level of unsecured creditors. I am unable to agree. A bankruptcy trustee cannot be treated as a judgment creditor except by giving that term an entirely artificial, fictional meaning. ”
