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UNITED STATES v. CANADIAN AMERICAN CO.

No. C. 11283.

108 F.Supp. 206 (1952)

UNITED STATES v. CANADIAN AMERICAN CO., Inc. et al.

United States District Court E. D. New York.

September 16, 1952.

Attorney(s) appearing for the Case

Frank J. Parker, U. S. Atty. for the Eastern District of New York, Brooklyn, N. Y. (George Taylor, Asst. U. S. Atty., Brooklyn, N. Y., and Homer R. Miller, Special Asst. to the Atty. Gen., of counsel), for United States.

Joseph Jaspan, Brooklyn, N. Y., for the Receiver.

G. Burchard Smith, Nassau County Atty., Mineola, N. Y. (Francis J. Donovan, Deputy Nassau County Atty., Mineola, N. Y., of counsel), for Nassau County.

J. Oakey McKnight, Mineola, N. Y., for Village of Old Westbury.

KENNEDY, District Judge.

This is an action to foreclose income tax liens, 26 U.S.C.A. §§ 3678, 3744. In its present posture the suit involves only the question of priorities of liens. The lien which the plaintiff seeks to foreclose arose on April 1, 1949, as a result of income tax delinquencies on the part of one James A. Wigmore for the calendar years 1943 and 1945 inclusive. The principal amount of these taxes exceeds $400,000, and if the interest and...

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