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UNITED STATES v. BAILEY

Civ. A. No. 5409.

137 F.Supp. 578 (1955)

UNITED STATES of America, Plaintiff, v. James E. BAILEY, New Milford Tractor Company, New Milford Oil Company, H. H. Taylor & Son, Leonard McMahon, Defendants.

United States District Court D. Connecticut.

July 16, 1955.

Attorney(s) appearing for the Case

Simon S. Cohen, U. S. Atty., Robert M. FitzGerald, Asst. U. S. Atty., Hartford, Conn., for plaintiff.

Norman S. Dube, New Milford, Conn., for N. M. Tractor Co.

James E. Bailey, per se.

Ferriss & Anderson, New Milford, Conn., for N. M. Oil Co.

Leonard McMahon, Danbury, Conn., per se.

J. JOSEPH SMITH, Chief Judge.

The issue in this case is the relative priorities to be accorded to liens of the plaintiff and defendants New Milford Oil Company and New Milford Tractor Company which have attached to the $3,646.72 belonging to the taxpayer Bailey as his share in his son's estate now held by defendant McMahon.

The government claims its tax liens arose under Section 3671 of Title 26 of the United States...

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