The HARTFORD PROVISION COMPANY, Plaintiff-Appellee,
v.
UNITED STATES of America, Defendant-Appellant.
United States Court of Appeals, Second Circuit.https://leagle.com/images/logo.png
Argued January 13, 1978.
Decided April 17, 1978.
Attorney(s) appearing for the Case
Aaron Rosenfeld, Washington, D. C. (M. Carr Ferguson, Asst. Atty. Gen., Dept. of Justice, Washington, D. C. and Gilbert E. Andrews, Crombie J. D. Garrett and Richard Blumenthal, Washington, D. C., of counsel), for defendant-appellant.
John J. Graubard, Stamford, Conn. (David M. Cohen, Washington, D. C., of counsel), for plaintiff-appellee.
Before MANSFIELD and VAN GRAAFEILAND, Circuit Judges, and DOOLING, District Judge.
United States Court of Appeals, Second Circuit.
VAN GRAAFEILAND, Circuit Judge:
In United States v. Security Trust & Savings Bank,340 U.S. 47, 71 S.Ct. 111, 95 L.Ed. 53 (1950), the Supreme Court held that a United States tax lien was prior in right to an earlier recorded attachment lien where the attaching creditor's claim had not yet proceeded to judgment. The court said that "[n]umerous contingencies might arise that would prevent...
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