LAYTON, District Judge.
The question presented for decision here is whether notice of a tax lien filed in the State of the taxpayer's residence was effective to make such tax lien valid as against an assignee of taxpayer's interest as beneficiary of a trust consisting of real property located in another state where notice of the lien was not filed.
The Commissioner of Internal Revenue assessed income taxes against the defendant Charles P. Gooding, as follows...
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