Appellant appeals from a summary judgment of the district court granting priority to the United States' tax lien claims over the judgment lien claim of the appellant. Both appellant and appellee agree that but for the provisions of Revised Statutes § 3466, 31 U.S.C. § 191, appellant would be entitled to priority. The district court held that section 3466 was applicable, with the consequence that the United States was entitled to priority, and that the appellant...
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