Crapper v. Berliner's Inc.

The issue is whether the United States has a tax lien having priority over competing claims to certain interpleaded funds.

McAllister, J., did not participate in this decision.

*119The delinquent taxpayer, Mrs. Parrish, operated a beauty parlor; she had numerous creditors. Mrs. Parrish contracted to sell the assets of her business to the Crappers, the plaintiffs. They thought that, possibly, the Bulk Sales Act (ch 76 ORS) was applicable ; therefore, they notified creditors of the proposed sale. The Crappers paid the sales price to Mr. Parker, attorney for the Crappers, who deposited it in his trust…