This section contains the nature of the case and procedural background.

The real property at issue was registered under the Torrens System in Minnesota. The United States (P) acquired a tax lien on the property and attempted to perfect it by filing notice of it by name only in the office of the register of deeds. A subsequent purchaser of the property (D) claimed that because P failed to perfect the lien in the manner prescribed by statute, it failed to acquire the lien.

The legal issues presented in this case will be displayed here.

The court's holding and decision will be displayed here.

Legal analysis from Dean's Law Dictionary will be displayed here.