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IN RE DeANGELIS

No. 15954.

373 F.2d 755 (1967)

In the Matter of Anthony DeANGELIS, Bankrupt. Walter D. Van Riper and Van Riper and Belmont, Appellants.

United States Court of Appeals Third Circuit.

Decided March 8, 1967.

Attorney(s) appearing for the Case

Frederic C. Ritger, Jr., Newark, N. J. (Van Riper & Belmont, Newark, N. J., on the brief), for appellants.

Vincent J. Commisa, Asst. U. S. Atty., Newark, N. J. (David M. Satz, Jr., U. S. Atty., Newark, N. J., on the brief), for appellee.

Before HASTIE, GANEY and SEITZ, Circuit Judges.

OPINION OF THE COURT

SEITZ, Circuit Judge.

We are concerned on this appeal with the issue of priority as between tax liens of the United States and the rights of a pledgee of an indebtedness owed the taxpayer.

Between the years 1954 and 1957 the United States made federal income tax assessments against Anthony DeAngelis totaling over $1,250,000. At various times notices and demands for payment were made. In 1957 the United States filed in the appropriate...

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