Silberman v. United States

Opinion

STEIN, J.

The United States appeals an order establishing the relative priority of claims to the proceeds of the sale of real property owned by *1536decedent Howard Silberman. The United States contends that, pursuant to the federal insolvency statute (31 U.S.C. § 3713) its unnoticed tax liens take priority over the prior recorded judgment liens of respondents Household Finance Corporation and Household Retail Services, Inc.

Facts

The executor filed a report of sale and a petition for an order confirming the sale of the property free and clear of liens and for distribution of the sale…