United States of America, Acting by and Through the Internal Revenue Service v. William R. Bradley, Trustee

GEWIN, Circuit Judge.

This is an appeal by the United States from an order of the District Court for the Northern District of Mississippi aifirming the opinion of the Referee in Bankruptcy, wherein he found that certain state and county tax liens, having arisen prior in time to certain United States tax liens, are superior to the latter and are to be paid out of the limited assets held by the trustee before the latter.

The United States argues that, although the local liens did arise first in time, the United States liens take first claim to the assets because the United States liens became…