CARDAMONE, Circuit Judge:
This appeal presents a single issue: which party is entitled to $16,400 in fire insurance proceeds — the sellers of real property damaged by fire who took a security interest in the "proceeds" of the property under the contract of sale, or the United States as tax lienor of the buyers? The law of New York clearly provides the government with a priority that, leaving sympathy aside, we are obliged to effectuate.
I
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