STRUM, Circuit Judge.
This is an appeal from a judgment of the district court subordinating tax liens of the United States to a lien held by a bank securing an indebtedness of the delinquent taxpayer to the bank.
The liens arose as follows: On January 16, 1947, one Gatzke procured a loan of $2120.00 from the appellee bank. The loan was evidenced by a promissory note, and secured by a bill of sale to the bank covering a Dodge automobile and the borrower's household...
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