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AIR POWER, INC. v. UNITED STATES

No. 83-1667.

741 F.2d 53 (1984)

AIR POWER, INC., Appellant, v. The UNITED STATES of America, Appellee.

United States Court of Appeals, Fourth Circuit.

Decided August 9, 1984.

Attorney(s) appearing for the Case

David Hugh Boyd, Fairfax, Va., for appellant.

William P. Wang, Tax Div., Dept. of Justice, Washington, D.C. (Elsie L. Munsell, U.S. Atty., Alexandria, Va., Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, William S. Estabrook, III, Tax Div., Dept. of Justice, Washington, D.C., on brief), for appellee.

Before HALL, MURNAGHAN and SPROUSE, Circuit Judges.

SPROUSE, Circuit Judge:

Air Power, Inc. (Air Power), appeals from the district court's decision granting a federal tax lien priority over its earlier state judgment lien against properties belonging to VWV Utility Construction Company, Inc. (VWV). The parties agree that Air Power's judgment lien was perfected under Virginia state law before the United States filed the required notice of its tax lien. 26 U.S.C. § 6323...

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