STEPHENSON, Chief Judge.
On January 23, 1959, the Commissioner of Internal Revenue made assessments of federal income taxes against the defendants Harry and Amanda Schroeder for the years 1944-1947 in the amount of $1,133,949.39. After demand and refusal to pay said taxes, notices of tax liens were filed pursuant to Iowa law in Fremont County (Fremont) and Mills County (Mills), Iowa on December 3 and December 12, 1959, respectively.
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