United States v. Tabor Court Realty Corp.

OPINION OF THE COURT

ALDISERT, Chief Judge.

We have consolidated appeals from litigation involving one of America’s largest anthracite coal producers that emanate from a district court bench trial that extended over 120 days and recorded close to 20,000 pages of transcript. Ultimately, we have to decide whether the court erred in entering judgment in favor of the United States in reducing to judgment certain federal corporate tax assessments made *1291against the coal producers, in determining the priority of the government liens, and in permitting foreclosure on the liens. To reach these questions,…