MADDEN, District Judge.
This matter was tried by the court without a jury and presented the following issues.
The plaintiff, United States of America, alleged the existence of two tax assessment liens, one dated December 28, 1944, in the amount of $12,908.80 (Exh.P. 1) and another dated September 18, 1945, in the amount of $18,145.76 (Exch.P. 2) for a total of $31,054.56 against the defendant Joseph Burgo, and it seeks by this suit to impose these liens upon...
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