SPRECHER, Circuit Judge.
What is the priority between a perfected tax lien and an earlier perfected chattel mortgage lien upon property not owned by the chattel mortgage debtor but owned by the taxpayer who had represented to the creditor that the debtor owned the property?
Three affiliated Parkhill corporations are involved: The parent corporation is Canadian Parkhill Pipe Stringing Ltd. ("Ltd."), which is the sole shareholder of the taxpayer, Canadian Parkhill...
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