United States v. The City of New York

FRANK, Circuit Judge.

Defendant claims (1) that there was insufficient admissible evidence to prove that warrants had been issued and notice of the sale given; (2) that even if such facts were proved, the court below erred in holding that they established compliance with the statutory requirements for proceedings on distraint by the Government; and (3) that even if compliance with the statutory requirements were established, the deeds conveyed only the title held by the taxpayer on December 17, 1942 and, hence, the property was still subject to the defendant’s liens attaching prior to that…