288 A Michigan statute purported to authorize the filing of federal tax lien notices with the county
register of deeds. However, the Michigan statute expressly required that notices of federal tax
liens upon real property contain "a description of the land upon which a lien is claimed." [2] The
standard tax lien notice form used by 289 the Treasury Department made no provision for such
a description, but was rather a blanket notice covering all property of the taxpayer in the
county. The Department had taken the position that § 3672 permitted state law to dictate the place …

UNITED STATES of America, Plaintiff-Appellant, v. ESTATE of Thomas S. DONNELLY, Sr., Oscar
A. Carlson and Genevieve S. Carlson, Defendants-Appellees … United States Court of Appeals
Sixth Circuit … Chester C. Davenport, Department of Justice, Washington, DC, Mitchell
Rogovin, Asst. Atty. Gen., Lee A. Jackson, John J. Gobel, Attorneys, Department of Justice,
Washington, DC, on brief; Lawrence Gubow, Detroit, Mich. (resigned) Now US Atty. Robert J.
Grace, Joseph F. Deeb, Jr., Asst. US Atty., Detroit, Mich., of counsel, for appellant … Daniel …

The facts are not in dispute and are as follows: On April 16, 1949, Thomas S. Donnelly, Sr. and
Jessie C. Donnelly, his wife, acquired by warranty deed certain property located in Livingston
County, Michigan. Said deed was properly recorded in Livingston County. On June 23,
1950, the Tax Court of the United States determined that Thomas S. Donnelly, Sr.,
individually, was liable for income taxes and penalties for the years 1943, 1944, 1945, in the
amount of about $26,000.00. Assessments of the taxes were made and notice of the tax liens …