Fine Fashions, Inc. v. United States of America, and Linde Factors Corp.

J. JOSEPH SMITH, Circuit Judge:

This action was brought in the United States District Court for the Southern District of New York by Fine Fashions, Inc. to resolve conflicting claims to a fund of $6,409.85 held by Linde Factors Corp. (Linde). Linde has disclaimed any interest in the fund and has deposited it in escrow with the United States Attorney. Fine Fashions claims the fund as the beneficiary of an assignment to Linde by the Penn Garment Co. (Penn) of payments due or to become due under a contract with the United States. The United States claims the fund under a tax lien against Penn.…