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SMITH v. ENOCHS

Civ. A. No. 1782(H).

233 F.Supp. 925 (1964)

In re S. O. SMITH et ux. v. J. L. ENOCHS, Director of Internal Revenue.

United States District Court S. D. Mississippi.

July 31, 1964.

Attorney(s) appearing for the Case

Curtis Breland, Leakesville, Miss., Williams S. Murphy, Lucedale, Miss., for plaintiff.

George R. Smith, Gulfport, Miss., Robert E. Hauberg, U. S. Atty., Jackson, Miss., for defendants.

COX, Chief Judge.

The plaintiffs have moved for a summary judgment under Civil Rule 56, supported by the pleadings, depositions and affidavits. The focal question thus presented is as to whether or not the plaintiffs are "purchasers" within the protection of § 6323(a), Internal Revenue Code 1954 against the lien of the defendant under § 6321, Internal Revenue Code 1954 against Samuel R. Bradley in the amount of eleven thousand four hundred fifteen dollars...

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