SHERIDAN, Chief Judge.
This action was tried to the court without a jury.
The complaint seeks to establish the priority of a lien of the United States on the settlement value of certain annuity contracts issued by defendant, The Equitable Life Assurance Society of the United States, to decedents, Patrick J. McCall and Helen McCall, and on real estate owned by Patrick J. McCall. It is alleged in Count 1, which relates to the annuity contracts, that the United...
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