MEMORANDUM OPINION
FLAUM, District Judge:
The present case requires this court to delve into the vagaries surrounding the "choateness" of state-created liens for the purpose of determining the priority between such a lien and a federal tax lien. The sole issue for decision in plaintiffs' motion for summary judgment is: Does section 6323 of the Internal Revenue Code of 1954, 26 U.S.C. § 6323, as amended, give plaintiffs' judgment lien priority...
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