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United States v. Scovil, 348 U.S. 218 (1955)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
United States v. Scovil, 348 U.S. 218 (1955)
United States v. Scovil No. 35 Argued November 16, 1954 Decided January 10, 1955 348 U.S. 218
CERTIORARI TO THE SUPREME COURT OF SOUTH CAROLINA
Syllabus
A tax lien of the United States under § 3670 of the Internal Revenue Code held entitled to priority over a landlord’s distress lien under South Carolina law where the distress lien was obtained (but not perfected) after the federal tax lien had attached, but before notice thereof had been filed. Pp. 218-221.
(a) Section 3672 affords no protection to the holder of a distress lien such as that here involved. P. 220.
(b) Whether the distress lien was perfected at the time the lien of the United States was filed is a question of federal law. P. 220.
(c) The distress lien in this case was not perfected in the federal sense at the time the liens of the United States were filed. P. 220.
(d) The landlord in this case was not a "purchaser" within the meaning of § 3672 of the Internal Revenue Code, and the tax lien of the United States was not invalid as to him under that section. Pp. 220-221.
224 S.C. 233, 78 S.E.2d 277, reversed.
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Chicago:
U.S. Supreme Court, "Syllabus," United States v. Scovil, 348 U.S. 218 (1955) in 348 U.S. 218 Original Sources, accessed July 1, 2025, http://www.originalsources.com/Document.aspx?DocID=8WLSCSA39J4WAX6.
MLA:
U.S. Supreme Court. "Syllabus." United States v. Scovil, 348 U.S. 218 (1955), in 348 U.S. 218, Original Sources. 1 Jul. 2025. http://www.originalsources.com/Document.aspx?DocID=8WLSCSA39J4WAX6.
Harvard:
U.S. Supreme Court, 'Syllabus' in United States v. Scovil, 348 U.S. 218 (1955). cited in 1955, 348 U.S. 218. Original Sources, retrieved 1 July 2025, from http://www.originalsources.com/Document.aspx?DocID=8WLSCSA39J4WAX6.
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