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UNITED STATES v. EQUITABLE LIFE

No. 645.

384 U.S. 323 (1966)

UNITED STATES v. EQUITABLE LIFE ASSURANCE SOCIETY OF THE UNITED STATES.

Supreme Court of United States.

Decided June 6, 1966.

Attorney(s) appearing for the Case

Robert S. Rifkind argued the cause for the United States. With him on the brief were Solicitor General Marshall, Acting Assistant Attorney General Roberts, Joseph Kovner and Richard J. Heiman.

Frank W. Hoak argued the cause for respondent. With him on the brief was Donald B. Jones.

MR. JUSTICE CLARK delivered the opinion of the Court.

This writ involves the recurring problem of priority contests between a state lien and a federal tax lien under §§ 6321 and 6322 of the Internal Revenue Code of 1954, 26 U. S. C. §§ 6321, 6322 (1964 ed.). Since 1950— United States v. Security Trust & Savings Bank, 340 U.S. 47—we have passed upon more than a dozen cases involving...

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