United States v. Canadian American Co.

KENNEDY, District Judge.

This is an action to foreclose income tax liens, 26 U.S.C.A. §§ 3678, 3744. In its present posture the suit involves only the question of priorities of liens. The lien which the plaintiff seeks to- foreclose a'rose on April 1, 1949, as a result of income tax delinquencies on the part of one James A. Wigmore for the calendar years 1943 and 194S inclusive. The principal amount of these taxes exceeds $400,000, and if the interest and penalties be -added the total amount of the lien is in excess of $800,000. Wigmore originally owned land in Nassau *207County which, through a…