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Criner’s name. Petitioner’s allegation of bias is not supported
by the record in this case.
A.2. Validity of the Nominee NFTL
Section 6321 provides:
SEC. 6321. If any person liable to pay any tax
neglects or refuses to pay the same after demand, the
amount (including any interest, additional amount,
addition to tax, or assessable penalty, together with
any costs that may accrue in addition thereto) shall be
a lien in favor of the United States upon all property
and rights to property, whether real or personal,
belonging to such person.
The language of section 6321 “is broad and reveals on its face
that Congress meant to reach every interest in property that a
taxpayer might have.” United States v. Natl. Bank of Commerce,
472 U.S. 713, 719-720 (1985); see also Drye v. United States, 528
U.S. 49, 56 (1999). Among the property interests reached by
section 6321 is an equitable interest owned by or for the benefit
of a taxpayer in property titled in the name of a nominee. G.M.
Leasing Corp. v. United States, 429 U.S. 338, 350-351 (1977);
United States v. Miller Bros. Constr. Co., 505 F.2d 1031 (10th
Cir. 1974). Section 6321 authorizes the Government, among other
things, to file a nominee NFTL against property of a taxpayer in
the hands of an alter ego or nominee. G.M. Leasing Corp. v.
United States, supra at 351.
Petitioner makes a vigorous and sometimes confusing attack
on the nominee NFTL utilized by respondent in this case. As we
understand petitioner’s arguments, they are as follows:
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