ANDERSON, Circuit Judge:
At the end of 1960 Julius Portner, who for fifteen years had been in the retail paint business under the name of J. P. Paint Co., found that he was insolvent, and in January of 1961 he initiated steps to work out a voluntary settlement with his creditors for twenty cents on the dollar. This endeavor came to naught, however, when the Federal Government levied upon his assets on March 15, 1961 to satisfy a $21,000 income tax liability. The assets...
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