OPINION
CAFFREY, District Judge.
This is a civil action of the United States seeking adjudication:
(1) that taxpayer-defendant Steven Kamieniecki is indebted to it for unpaid federal income taxes, penalties and interest for the years 1956 and 1957 in the total amount of $6289.36, plus interest;
(2) that the United States has valid and first liens in said amount upon the proceeds of a Certificate of Deposit issued by the Indian Head National...
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