LUMPKIN, District Judge.
This is a case to test the relative merits of two liens. One lien was established by the statutes of the United States of America, Section 3321(b), 26 U.S.C.A., of the Internal Revenue Code of 1939 and Title 27, U.S.C.A. § 40a. The other lien was established by Section 8785 of the 1932 Code of South Carolina. The case came before me on a stipulated finding of facts as set out below.
Findings of Fact.
On or about May...
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