There are three federal tax liens which serve to haunt the average title examiner. The first of these is pitched at the wholesale level; it is a shotgun type lien applicable to all federal taxes and is now provided for by section 3670 of the Internal Revenue Code. The second and third are not nearly so sweeping. One is confined to the federal estate tax, being provided for by section 827 of the code, while the other reinforces the federal gift tax and is the product of section 1009 of the code.

The discussion which follows deals only with the first, the most general, of the three liens, and then only insofar as it affects the examination of titles in Michigan. The present inquiry is circumscribed by this geographical limitation only because Michigan stands almost alone in failing to come to an agreement with the federal authorities as to the requirements which should be satisfied before such a lien will be valid as against good faith purchasers. Accordingly, title examiners of this state who encounter this lien face problems which are not shared by practitioners in other states.