OPINION
DAVID E. NIMS, Jr., Bankruptcy Judge.
This is an action by Cleon Township and Manistee County to recover the unpaid personal property taxes on an oil well drilling rig for the year 1982. This action involves the relative priorities of the tax lien of the taxing units and the consensual lien of Harris Trust & Savings Bank (Harris).
Manistee County and Cleon Township are making the same claim and hereafter will be referred to collectively...
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