Sherman Minton

“ A cardinal principle of Congress in its tax scheme is uniformity, as far as may be. Therefore, a 'judgment creditor' should have the same application in all the states. In this instance, we think Congress used the words 'judgment creditor' in § 3672 in the usual, conventional sense of a judgment of a court of record, since all states have such courts. ”

“ In the office of the clerk of the United States district court for the judicial district in which the property subject to the lien is situated * * *.' The Supreme Court of New Hampshire held that since notice of the Government's lien was not filed until August 6, 1948, and the Town's taxes were assessed on April 1, 1947, and April 1, 1948, respectively, and such tax assessments are 'in the nature of a judgment' under the law of New Hampshire, the Town was a judgment creditor within the meaning of § 3672, and the Government's lien was not valid as against the Town's. ”

“ Property subject to lien↑ R.S. § 3466. 'Whenever any person indebted to the United States is insolvent, or whenever the estate of any deceased debtor, in the hands of the executors or administrators, is insufficient to pay all the debts due from the deceased, the debts due to the United States shall be first satisfied ”