in favor of the United States upon all property and rights to property, whether real or personal, belonging to such person.” “The threshold question ... in all cases where the Federal Government asserts its tax lien, is whether and to what extent the taxpayer had property or rights to property to which the tax lien could attach.” Aquilino v. United States, 363 U.S. 509, 512, 80 S.Ct. 1277, 4 L.Ed.2d 1365 (1960) (internal quotation marks omitted). “[A]l-though state law creates legal interests and rights in property, federal law determines whether and to what extent thos ndard of “choateness” before the federal tax hen arises can prime a federal tax lien. See United States v. Equitable Life Assurance Society of the United States, 384 U.S. 323, 328, 86 S.Ct. 1561, 16 L.Ed.2d 593 (1966) (<HOLDING>). A state-created lien is choate only when
holding that a public administrator was not entitled to attorneys fees in a claim against the estate of a former guardian where the case was not one where attorneys fees were authorized and there was no evidence to support the award holding that a federal tax lien was entitled to priority over a mortgagees inchoate claim for attorneys fees holding trial court erred in awarding attorneys fees to physicians in absence of any evidence of attorneys fees holding party should have segregated attorneys fees for fraud claim from attorneys fees for contract claim based largely on the difference between the essential elements of each claim holding that plaintiffs are entitled to attorneys fees for time spent litigating the fees issue on appeal under title viis attorneys fee provision