GRONER, District Judge.
Section 3186, R. S. (Comp. St. § 5908), provides as follows:
"If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount shall be a lien in favor of the United States from the time when the assessment list was received by the collector, except when otherwise provided, until paid, with the interest, penalties," etc. "Provided, however, That such lien shall not be valid as against any mortgagee...
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