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UNITED STATES v. ARLINGTON

Nos. 81-1094, 81-1125.

669 F.2d 925 (1982)

UNITED STATES of America, Appellee, v. COUNTY OF ARLINGTON, VIRGINIA, Appellant. and Bennie L. Fletcher, Jr., Treasurer of the County of Arlington, Virginia, Defendant. UNITED STATES of America, Appellant, v. COUNTY OF ARLINGTON, VIRGINIA, and Bennie L. Fletcher, Jr., Treasurer of the County of Arlington, Virginia, Appellees.

United States Court of Appeals, Fourth Circuit.

Decided February 1, 1982.

Attorney(s) appearing for the Case

John J. McCarthy, Tax Division, Dept. of Justice, Washington, D. C. (Justin W. Williams, U. S. Atty., Alexandria, Va., John F. Murray, Acting Asst. Atty. Gen., Michael L. Paup, David English Carmack, Tax Division, Dept. of Justice, Washington, D. C., on brief), for appellant.

Charles G. Flinn, Deputy County Atty., Arlington, Va. (Jerry K. Emrich, County Atty., Arlington, Va., on brief), for appellees.

Before BUTZNER and SPROUSE, Circuit Judges, FIELD, Senior Circuit Judge.

BUTZNER, Circuit Judge:

This appeal involves the tax status of an apartment building owned by the German Democratic Republic (GDR) in Arlington County, Virginia. The district court ruled (1) the county could not assess taxes on the property after May 4, 1979; (2) the property was subject to a tax lien for 1977, 1978, and part of 1979, which the county could presently execute; (3) the United States was collaterally estopped from litigating whether the property is exempt...

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