United States v. Samel Refining Corp.

OPINION

HANNUM, District Judge.

This is a suit to foreclose federal tax liens upon a sum of money deposited with the defendant First Federal Savings and Loan Association. Presently before the court are cross motions for summary judgment, one by E. F. Drew & Co., Inc. (hereinafter “Drew”) one of the defendants, and one by the United States of America, the plaintiff herein. Since the facts are not in dispute and have been stipulated, there is presented solely an issue of law as to which of these parties is entitled to the fund in question. The claim of each of the moving parties exceeds the…