United States v. Commonwealth

SIMS, Judge.

The two major questions for determination on this appeal are: 1. Did the income tax lien of the Commonwealth for $3,862.80 for the year 1951 attach or become perfected on certain funds of the delinquent taxpayer, Ed W. Curd, before the federal income tax lien for 1952 attached or became perfect on these same funds; 2. did the income tax lien of the federal government for 1952 ever attach or become perfected on these funds of Curd so as to give the United States priority over the Commonwealth’s lien for $15,069.80 for income tax Curd owed the Commonwealth for the years 1941 to 1950…