ROSELLINI, J.
This appeal involves a dispute between the United States and the state of Washington as to the priorities of their respective liens against the proceeds of a mortgage and lien-foreclosure sale of a parcel of real estate located in Spokane county, belonging to the defendant Electrovation, Inc. It is before us on an agreed statement of facts, which reveals that the Federal government's liens for withholding tax, Federal insurance contributions, and
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