Court of Appeals for the Tenth Circuit October 6, 1976, 75-1273 (United States v. United Banks of Denver, as Trustee of the Trust Created by the Last Will of Carl J. Martinson, and William Arthur Martinson)

McWILLIAMS, Circuit Judge.

The issue as posed by the parties is whether the taxpayer’s interest in a trust fund established by his father’s will constitutes “property” or “rights to property” to which a federal tax lien may attach under Section 6321 of the Internal Revenue Code of 1964. As will be developed, we view the issue before us to be much narrower.