LITTLETON, Judge.
In so far as the question presented in this case is concerned, plaintiff was engaged in the business of purchasing from counties and municipalities delinquent real estate taxes annually advertised and offered for sale by such counties and municipalities; such delinquent taxes constituted under the laws of political subdivisions of states first liens on the real property of the taxpayer and carried legal interest of from 10 to 12 per cent. per annum...
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