CONNELL, Chief Judge.
On April 23, 1964 the Internal Revenue Service assessed a tax deficiency in the amount of $4988.03 against S & C Tavern, Inc. A lien for this amount was filed for record in the Cuyahoga County Recorder's Office on May 18, 1964. On April 27, 1964 the Government had seized the business of that tavern, including the furniture, fixtures, contents of the cash register and purported to seize the "right, title and interest of S & C Tavern, Inc...
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