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U.S. v. PARK TOWERS, INC.

No. 93-3021.

8 F.3d 306 (1994)

UNITED STATES of America, Plaintiff-Appellant, v. PARK TOWERS, INC., et al., Defendants, Charles I. Denechaud, III and the Roman Catholic Church of Archdiocese of New Orleans, Defendants-Appellees.

United States Court of Appeals, Fifth Circuit.

Rehearing Denied January 7, 1994.

Attorney(s) appearing for the Case

Gilbert S. Rothenberg, U.S. Dept. of Justice, Tax Div., Gary R. Allen, Chief, Appellate Section, and Bridget M. Rowan, Tax Div., U.S. Dept. of Justice, Washington, DC, for plaintiff-appellant.

Jerome J. Reso, Jr. and Jeannie M. Randazzo, Baldwin & Haspel, New Orleans, LA, for Denechaud and Roman Catholic Church.

Before POLITZ, Chief Judge, REAVLEY and EMILIO M. GARZA, Circuit Judges.

REAVLEY, Circuit Judge:

The United States initiated suit to reduce its tax assessments against Park Towers, Inc. ("Park Towers") to judgment and to foreclose on federal tax liens against that corporation's interest in the assets of the Park Tower Apartments Partnership ("The Louisiana Partnership"). The Archdiocese of New Orleans claimed to be a creditor of the Louisiana Partnership, however, and thus to enjoy priority over the United States, a creditor only of the...

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