Aquilino v. United States

This appeal, here by our permission, involves the relative priority between a mechanic’s lien and a federal tax lien.

Fleetwood Paving Corporation owes the United States Government a sum of money representing unpaid withholding and social security taxes. In December, 1951 and March, 1952, the local collector received assessment lists including assessments against the taxpayer. Some short time later, Fleetwood, as general contractor, entered into an agreement with one Ada *514Bottone to remodel a restaurant which she owned in the Town of Eastchester. Thereafter, in August and September of that same…