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UNITED STATES v. CITY OF GREENVILLE

Nos. 4748, 4749.

118 F.2d 963 (1941)

UNITED STATES v. CITY OF GREENVILLE et al. (two cases). UNITED STATES v. WOODSIDE et al.

Circuit Court of Appeals, Fourth Circuit.

April 7, 1941.

Attorney(s) appearing for the Case

Courtnay C. Hamilton, Sp. Asst. to Atty. Gen. (Samuel O. Clark, Jr., Asst. Atty. Gen., Sewall Key, Sp. Asst. to Atty. Gen., and Oscar Henry Doyle, U. S. Atty., of Anderson, S. C., on the brief), for appellant.

Wilton H. Earle, of Greenville, S. C. (A. C. Mann, of Greenville, S. C., on the brief), for appellees.

Before PARKER, SOPER and DOBIE, Circuit Judges.

PARKER, Circuit Judge.

This is an appeal in two suits instituted under R.S. 3207, 26 U.S.C.A. Int.Rev.Code, § 3678, to foreclose liens of the United States for income taxes due by Robert I. Woodside and John T. Woodside on real estate owned by them. The court below held that tax claims of the State of South Carolina and the County of Greenville and tax and special assessment claims of the City of Greenville were liens prior to the liens of the United States and...

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