MEMORANDUM AND ORDER
TROUTMAN, District Judge.
This is an action by the United States Government to foreclose Federal tax liens in accordance with I.R.C. § 7403 on funds in a bank account belonging to the defendant-taxpayer, L.D.T. Corporation. The defendants, William C. Stein and Elaine Leibowitz, executrix of the Estate of Martin C. Stein, claim they have priority to those funds. The defendant The First Pennsylvania Banking and Trust Company is merely...
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