United States v. Taft

HARRISON, District Judge.

This action involves the determination of the priority between a tax lien created under the provisions of Sections 3670 and 3671 of the Revenue Code, 26 U.S.C.A. Int. Rev.Code, §§ 3670, 3671, and a lien created by the levy of an execution by the Citizens National Trust & Savings Bank of Los Angeles. The sole question involved is whether or not the lien created by said sections attaches to after-acquired property. The case was submitted on a written stipulation of facts.

The facts, in so far as they are pertinent to this case, disclose that during the year 1931, the…