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PLANTERS NAT. BANK & TRUST CO. v. SOUTH CAROLINA INS. CO.

No. 249.

138 S.E.2d 812 (1964)

263 N.C. 32

The PLANTERS NATIONAL BANK & TRUST COMPANY OF ROCKY MOUNT, N. C. v. SOUTH CAROLINA INSURANCE COMPANY.

Supreme Court of North Carolina.

November 19, 1964.

Attorney(s) appearing for the Case

W. S. Wilkinson and James W. Keel, Jr., Rocky Mount, for plaintiff.

Jeff D. Batts and Cary Whitaker, Rocky Mount, for defendant.

DENNY, Chief Justice.

It is provided in 26 U.S.C.A. § 6321, "If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount * * * shall be a lien in favor of the United States upon all property and rights to property, whether real or personal, belonging to such person."

It is further provided in 26 U.S.C.A. § 6322: "Unless another date is specifically fixed by law, the lien imposed by section 6321 shall arise at...

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