United States v. Grubert

INGRAHAM, District Judge.

This is an action on behalf of the United States of America to foreclose a federal tax lien pursuant to Sections 7401, 7402 and 7403 of the Internal Revenue Code of 1954 (26 U.S.C.A. § 7401, et seq.). Defendants are taxpayer Harry R. Grubert, stakeholder Texas Title Company (hereinafter Texas Title), and William B. Jeter, one-time counsel for Gru-bert, who asserts a prior lien for attorney’s fees on property of Grubert held by Texas Title. The dispute boils down to one as to priority of claims between the United States and Jeter. The case is here on motions for…