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A. H. AND R. S. COAL CORP. v. UNITED STATES

Civ. A. No. 75-94.

461 F.Supp. 752 (1978)

A. H. AND R. S. COAL CORPORATION and Robert Snyder, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, W. D. Pennsylvania.

July 17, 1978.

Attorney(s) appearing for the Case

John E. Wall, Pittsburgh, Pa., for plaintiffs.

Thomas A. Daley, Asst. U. S. Atty., Pittsburgh, Pa., Gregory S. Hrebiniak, Tax Div., U. S. Dept. of Justice, Washington, D. C., for defendant.

OPINION

MARSH, District Judge.

Plaintiffs A. H. and R. S. Coal Corporation and Robert Snyder have instituted an action to quiet title, seeking divestment of a federal tax lien on personal property which they purchased. After a non-jury trial, the court makes the following findings of fact and conclusions of law.

The personal property purchased by plaintiffs had been subject to a security interest granted by a previous owner, American International...

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