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UNITED STATES v. VERMONT

No. 509.

377 U.S. 351 (1964)

UNITED STATES v. VERMONT ET AL.

Supreme Court of United States.

Decided June 1, 1964.

Attorney(s) appearing for the Case

Daniel M. Friedman argued the cause for the United States. With him on the briefs were Solicitor General Cox, Assistant Attorney General Oberdorfer and Joseph Kovner.

Charles E. Gibson, Jr., Attorney General of Vermont, argued the cause and filed a brief for respondents.

MR. JUSTICE STEWART delivered the opinion of the Court.

This case involves a conflict between two liens upon the property of a solvent Vermont taxpayer—a federal tax lien arising under the provisions of 26 U. S. C. §§ 6321 and 63221 and an antecedent state tax lien based on a Vermont law worded in terms virtually identical to the provisions of those federal statutes.

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