MATTHES, Circuit Judge.
We have for determination the question of whether the lien of the Government for unpaid taxes is entitled to priority over the rights of appellant which were created by a document denominated as a "conditional sale contract" antedating the assessment and filing of the notice of the tax lien.
On May 1, 1956, the appellant agreed to sell to Basin Rig & Trucking, Inc. (Basin), certain personal property in accordance with the terms...
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