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UNITED STATES v. SAMEL REFINING CORPORATION

No. 19322.

461 F.2d 941 (1972)

UNITED STATES of America, Appellant, v. SAMEL REFINING CORPORATION et al.

United States Court of Appeals, Third Circuit.

Decided June 2, 1972.

Attorney(s) appearing for the Case

Janet R. Spragens, Dept. of Justice, Tax Div., Washington, D. C., for appellant.

Allen J. Levin, Goodis, Greenfield, Narin & Mann, Philadelphia, Pa., for appellee.

Before KALODNER, STALEY and ADAMS, Circuit Judges.

OPINION OF THE COURT

STALEY, Circuit Judge.

The United States of America brought this action to foreclose Federal tax liens upon a sum of money deposited with the defendant, First Federal Savings and Loan Association.

The facts are not in dispute and were stipulated in the district court. In 1961, Samel Refining Corporation ("Samel"), the taxpayer, entered into a five-year lease with Bernstein & Bernstein Realty Corporation for certain premises...

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