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UNITED STATES v. MILLER BROTHERS CONSTR. CO.

No. 74-1028.

505 F.2d 1031 (1974)

UNITED STATES of America, Plaintiff-Appellee, v. MILLER BROTHERS CONSTRUCTION COMPANY et al., Defendants, Rapidways, Inc., Defendant-Appellant.

United States Court of Appeals, Tenth Circuit.

Decided November 13, 1974.

Attorney(s) appearing for the Case

Robert L. Boyce, Jr., Kansas City, Kan. (Howard Washburn, Kansas City, Kan., on the brief), for defendant-appellant.

Daniel F. Ross, Washington, D. C. (Scott P. Crampton, Asst. Atty. Gen., Meyer Rothwacks, Michael L. Paup, Dept. of Justice, Robert J. Roth, U. S. Atty., James A. Pusateri, Asst. U. S. Atty., Washington, D. C., on the brief), for plaintiff-appellee.

Before LEWIS and HILL, Circuit Judges, and CHRISTENSEN, District Judge.

HILL, Circuit Judge.

This is an appeal from a judgment of the United States District Court for the District of Kansas ordering foreclosure of federal tax liens against certain real property, the ownership of which is in dispute.

The facts leading up to this appeal are complex and may be summarized as follows. Anthony Sielman owned certain land in Kansas City, Kansas. In 1952, Wilmer Miller (taxpayer) purchased this land but directed Sielman to deed it to Edward...

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