Congress has been attempting to eliminate secret liens under the bankruptcy act for years. The battle has once again been joined over the question of whether a trustee in bankruptcy is a judgment creditor within the meaning of section 3672(a) of the Internal Revenue Code. Although Congressional intent appears to clearly indicate that he is, the question has been brought into sharp focus by several recent decisions.

I. Introduction

II. Interpretation of Congressional Intention … A. By Examination of Legislative Reports … B. By Comparison to Other Sections of the Act

III. Tracing Section 3672(a) of the Internal Revenue Code

IV. Statutory Construction

V. Summary and Analysis

VI. Conclusion