United States v. Craft

Summary

The Court held that a spouse's interest in Michigan tenancy-by-the-entirety property constitutes property or rights to property to which a federal tax lien may attach under 26 U.S.C. § 6321. State law defines the taxpayer's rights, but federal law determines whether those rights qualify under the statute; Michigan's characterization of the marital estate and its protections against individual creditors do not control that determination. The Court reversed and remanded without deciding the proper valuation of the husband's interest. Justice Scalia dissented, joined by Justice Thomas, emphasizing the decision's erosion of protections for stay-at-home spouses and also joining Thomas's dissent. Justice Thomas dissented, joined by Justices Stevens and Scalia, arguing that Michigan law gave the husband neither individually owned property nor particular rights to property susceptible to the lien, and that the majority improperly displaced state property law.