United States v. City of Los Angeles

DECISION, FINDINGS OF FACT AND CONCLUSIONS OF LAW, AND ORDER FOR JUDGMENT FOR PLAINTIFF

HAUK, District Judge.

This is an action for enforcement of Internal Revenue levy and for collection of Internal Revenue taxes for failure to honor levy. Jurisdiction is conferred upon this Court by 28 U.S.C. Sections 1340 and 1345 and 26 U.S.C. Section 7402. The specific question posed is whether a tax lien of the United States, hereafter the Government, perfected prior to and superior to a State tax lien is subordinated by the State lien under the State’s theory that their lien is that of a judgment…