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LEISCHNER v. ALLDRIDGE

No. 56639-9.

114 Wn.2d 753 (1990)

790 P.2d 1234

RICKEY C. LEISCHNER, ET AL, Respondents, v. WILLIAM E. ALLDRIDGE, ET AL, Defendants, THE UNITED STATES OF AMERICA, Appellant.

The Supreme Court of Washington, En Banc.

May 10, 1990.

Attorney(s) appearing for the Case

Gene S. Anderson, United States Attorney; Gary R. Allen, William S. Estabrook, and Stuart E. Horwich, Assistant Attorneys of the United States; and Shirley D. Peterson, Assistant Attorney General, for appellant.

Janet Lim (of Petersen, Lycette & Snook, P.S.), for respondents.

DOLLIVER, J.

The United States of America, through its agency, the Internal Revenue Service (IRS), challenges a superior court determination that a federal tax lien is inferior to a litigant's claim for attorney fees where the source of the funds available for satisfaction of the competing claims are interpleaded funds resulting from the litigants' action to quiet title.

Plaintiffs brought an action to quiet title...

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