INGRAHAM, District Judge:
This is an appeal from a summary judgment adjudicating priority of liens. The question presented is whether a federal tax lien is entitled to priority over a personal judgment which was obtained by the appellant against the taxpayer before the federal lien was recorded but which did not constitute a lien on the taxpayer's personal property and which had not been levied upon at the time of recordation.
In March, 1963, J. P. Duncan...
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