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CITIZENS CO-OP GIN v. UNITED STATES

No. 28136.

427 F.2d 692 (1970)

CITIZENS CO-OP GIN et al., Plaintiffs-Appellees, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Fifth Circuit.

June 16, 1970.

Attorney(s) appearing for the Case

Johnnie M. Walters, Asst. Atty. Gen., Tax Div., Lee A. Jackson, Stephen H. Hutzelman, Crombie D. Garrett, Attys., Dept. of Justice, Washington, D. C., Earl R. Allison, Levelland, Tex., Edward W. Napier, Lubbock, Tex., Eldon B. Mahon, U. S. Atty., Fort Worth, Tex., for defendant-appellant.

J. R. Blumrosen, Thomas J. Griffith, Lubbock, Tex., for plaintiffs-appellees.

Before WISDOM, GOLDBERG and INGRAHAM, Circuit Judges.

GOLDBERG, Circuit Judge:

The Commissioner of Internal Revenue contests an adverse judgment of the court below regarding the relative priority of a federal tax lien. The Commissioner asks us to narrowly construe the Federal Tax Lien Act, ignoring the fact that its very genesis was in generosity. Looking to the Congressional intent underlying the statute, we refuse to subvert its tolerant purpose in such a fashion.

The taxpayers, J. B. and Leola Marion, were...

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