528 U.S. 49 (1999)
Rohn F. Drye, Jr., was insolvent and owed the Federal Government some $825,000 on unpaid tax assessments for which notices of federal tax liens had been filed at the time of his mother’s death.1 On August 3, 1994, his mother Irma Deliah Drye died intestate, leaving an estate worth approximately $233,000, of which $158,000 was personalty and $75,000 was realty located in Pulaski County, Arkansas.2 Drye was sole heir to the estate under Arkansas law.3
Drye petitioned the Pulaski County Probate Court for appointment as administrator of his mother’s estate and was so appointed on August 17, 1994.4 Almost six months later, on February 4, 1995, Drye filed in the Probate Court and land records of Pulaski County a written disclaimer of all interests in his mother’s estate.5 Two days later, Drye resigned as administrator of the estate.6 Drye’s disclaimer caused the estate to pass to his daughter, Theresa Drye, who succeeded her father as administrator and promptly established the Drye Family 1995 Trust.7
Theresa Drye used the estate’s proceeds to fund the Trust, of which she and, during their lifetimes, her parents are the beneficiaries.8 During negotiations in 1995 regarding Drye’s tax liabilities, Drye revealed to the IRS his beneficial interest in the Trust.9 On April 11, 1996, the IRS filed with the Pulaski County Circuit Clerk and Recorder a notice of federal tax lien against the Trust as Drye’s nominee and served a notice of levy on accounts held in the Trust’s name by an investment bank.10
On May 1, 1996, the Trust filed a wrongful levy action against the United States in the United States District Court for the Eastern District of Arkansas.11 The Government counterclaimed against the Trust, the trustee, and the trust beneficiaries, seeking to reduce to judgment the tax assessments against Drye, confirm its right to seize the Trust’s assets, foreclose on its liens, and sell the Trust property.12 On cross-motions for summary judgment, the District Court ruled in the Government’s favor.13 The United States Court of Appeals for the Eighth Circuit affirmed the District Court’s judgment.14 The Supreme Court granted certiorari to resolve a conflict between the Eighth Circuit’s holding and decisions of the Fifth and Ninth Circuits.15
Whether Drye’s interest as heir to his mother’s estate constituted “property” or a “righ[t] to property” to which the federal tax liens attached under 26 U.S.C. § 6321, despite Drye’s exercise of the prerogative state law accorded him to disclaim the interest retroactively?16
Under 26 U.S.C. § 6321, if any person liable to pay any tax neglects or refuses to pay the same after demand, the amount 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.17 The language in §§ 6321 and 6331(a) is broad and reveals on its face that Congress meant to reach every interest in property that a taxpayer might have.18
The question whether a state-law right constitutes property or rights to property is a matter of federal law.19 Courts look initially to state law to determine what rights the taxpayer has in the property the Government seeks to reach, and federal law then determines whether the taxpayer’s state-delineated rights qualify as property or rights to property within the compass of the federal tax lien legislation.20
Once it has been determined that state law creates sufficient interests in the taxpayer to satisfy the requirements of the federal tax lien provision, state law is inoperative to prevent the attachment of liens created by federal statutes in favor of the United States.21
Yes. Drye’s interest as heir to his mother’s estate constituted property or a right to property to which the federal tax liens attached under 26 U.S.C. § 6321, and his disclaimer did not defeat those liens.22 The established facts show that on August 3, 1994, upon the death of Irma Deliah Drye, Drye acquired under Arkansas law a valuable, transferable, legally protected right to the estate worth approximately $233,000 as sole heir.23 This right included the unqualified authority either to receive the entire value of the estate or to channel that value to his daughter Theresa Drye by disclaiming.24
Although Drye filed a written disclaimer on February 4, 1995, causing the estate to pass to the Drye Family 1995 Trust, federal law controls the classification of that interest as property.25
Drye’s interest as heir constituted property or rights to property to which the federal tax liens attached under 26 U.S.C. § 6321, and his disclaimer did not prevent the attachment.26