Court precedent and should be reversed. I therefore write separately to identify the bases for my disagreement with Craft I and to recommend that this case be revisited en banc. As Judge Ryan pointed out in his dissent in Craft I, the legal landscape has changed considerably since 1971, when this court held in Cole v. Cardoza, 441 F.2d 1337, 1343 (6th Cir.1971), that a federal tax lien against an individual taxpayer cannot attach to property held by that taxpayer as a tenant by the entirety. In the interim, the Supreme Court has made clear that the IRS’s power under 26 U.S.C. § 6321 to attach the individual property rights of a delinquent taxpayer is extensive, if not plenary. See United States v. National Bank of Commerce, 472 U.S. 713, 719-20, 106 S.Ct. 2919, 86 L.Ed.2d 565 (1985) (<HOLDING>); Jewett v. Commissioner of Internal Revenue,
holding that any property in which the taxpayer has any right title or interest is subject to foreclosure proceeding including property in which others claim an interest so long as all persons having liens or claiming any interest in the property are joined as parties to the suit holding that  6321 is broad and reveals on its face that congress meant to reach every interest in property that a taxpayer might have holding that  7403 requires compensation for every property interest that is taken in the process holding that plaintiffs may have a property interest in real property holding that inmates have a property interest in their money