I'm often referred to as the 'secret lien' because initially my existence is known only by the IRS and the taxpayer. My lien is effective without the filing of a public notice. The Supremacy Clause of the U.S. Constitution prevents any local or state recording acts from otherwise interfering with my attachment to all property and rights to property of the debtor taxpayer. But if you are not one of those lucky so-called 'super priorities' then you are subject to my lien on a 'first in time, first in line' basis beginning with the date of assessment even though you didn't know, and had no way of knowing, of my existence. If the lien attaches to everything then it attaches to a beneficiary's share of an estate even if the beneficiary files a disclaimer.
Federal law governs issues of federal tax lien priority.
But state law controls for purposes of determining the nature of the legal interest in the property to be reached by the statute. State law creates legal interests and rights in property, but federal law determines whether and to what extent those interests will be taxed. Federal tax laws do not create property rights but merely attach consequences, federally defined, to rights created under state law. That's where I come into the picture. We need to determine whether, under applicable state law, the beneficiary has a property interest in a disclaimed or renounced share of an estate before we can determine whether Section 6321's lien has anything to attach.