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UNITED STATES v. FIDELITY PHILADELPHIA TRUST CO.

No. 71-1277.

459 F.2d 771 (1972)

UNITED STATES of America, Appellant, v. FIDELITY PHILADELPHIA TRUST CO. et al.

United States Court of Appeals, Third Circuit.

Decided May 2, 1972.

Attorney(s) appearing for the Case

Issie Jenkins, Department of Justice— Tax Division, Washington, D. C., for appellant.

Samuel Kagle, Philadelphia, Pa., for appellees.

Before McLAUGHLIN, VAN DUSEN and ALDISERT, Circuit Judges.

OPINION OF THE COURT

ALDISERT, Circuit Judge.

This appeal by the government from an order of the district court, 321 F.Supp. 7, awarding $5,000 to attorney claimants from an escrow fund requires us to decide whether the claimants had perfected an attorney's lien under Pennsylvania law and were, therefore, entitled to priority over a federal tax lien.

The government brought an action in the district court seeking...

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