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U.S. v. BARAN

No. 1228, Docket 92-6279.

996 F.2d 25 (1993)

UNITED STATES of America, Plaintiff-Appellee, v. Zenowia BARAN, Ostap Baran, and Self Reliant (NY) Federal Credit Union, Defendants-Appellants, Joseph F. Farano, Maria Farano, Joseph M. Farano, Phyllis Marie Farano, and Hartford Accident & Indemnity Co., Defendants.

United States Court of Appeals, Second Circuit.

Decided June 14, 1993.

Attorney(s) appearing for the Case

Burton Aronson, Garden City, NY (Samuel Kirschenbaum, Kirschenbaum & Kirschenbaum, on the brief), for defendants-appellants.

Gabriel W. Gorenstein, Asst. U.S. Atty., New York City (Roger S. Hayes, U.S. Atty. and Ping C. Moy, Asst. U.S. Atty., on the brief), for plaintiff-appellee.

Before: NEWMAN and MAHONEY, Circuit Judges, and EGINTON, District Judge.

JON O. NEWMAN, Circuit Judge:

This appeal primarily concerns whether a United States tax lien should be subordinated to the junior lien of a mortgagee through the doctrine of equitable subrogation. The issue arises on the appeal of Zenowia Baran, Ostap Baran, and Self Reliant (NY) Federal Credit Union ("Self Reliant") from the October 26, 1992, judgment of the District Court for the Southern District of New York (Miriam Goldman...

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