PER CURIAM.
The sole question involved in this appeal is the priority of the lien of the Government for income taxes over that of a pledgee of shares of stock to secure payment of a loan.
This depends on whether the pledgee had "notice or knowledge of the existence of such lien" for income taxes on the date the stock was pledged. Internal Revenue Code of 1939, § 3672(b) (1), 26 U.S.C. § 3672.
The burden of proof was on the Government to establish...
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