Sears Roebuck & Co. v. Stockwell

DEVITT, District Judge.

The question for decision is as to the proper interpretation of the Federal Tax Lien Notice statute as it relates to the Minnesota title recordation laws. The issue is as to the priority to be accorded to the claims of the United States and a judgment creditor to a fund in the registry of the court.

This action was started against Louis Stockwell; the relief sought was the imposition of a constructive trust upon certain real estate in Hennepin County, Minnesota. That cause of action is of no import here since the original plaintiff, Sears Roebuck, has elected to proceed…