JOHNSON, Judge.
The appellant, Revenue Cabinet for the Commonwealth of Kentucky (hereinafter "Cabinet"), has appealed a summary judgment of the Fayette Circuit Court which held that a judgment lien of appellee, Liberty National Bank of Lexington (hereinafter "Liberty"), is prior and superior to the tax lien of the Cabinet. The issue in this case is whether a tax lien resulting from a jeopardy assessment pursuant to KRS 131.150 and filed by the Cabinet pursuant to...
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