In the Matter of Airmotive Suppliers, Inc., Bankrupt. United States of America v. Jeanette Tavormina, Trustee

RIVES, Circuit Judge:

The trustee in bankruptcy filed in the bankruptcy court his petition for a determination as to the validity of any claim by the Internal Revenue Service for pre-petition penalties and post-petition penalties against the bankrupt [App. 7]. After a hearing, the Referee or Bank ruptcy Judge “ORDERED, ADJUDGED and DECREED . . . that the Government has no lien on or claim to the notes and proceeds for any penalties due or claimed to be due on the notes held by it or the proceeds therefrom” [App. 80]. On petition for review the district court affirmed that judgment [App. 88].…