DENMAN, Circuit Judge.
This is an appeal from a judgment declaring that the County of Fresno has no lien under the California law upon certain cotton situate in that county by reason of the assessment of its value for taxation to its owner, or its sequestration for the owner's unpaid taxes, which is superior to a lien upon it, created prior to the assessment and sequestration, to secure a loan by the appellee under the provisions of the Agricultural Adjustment Act...
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