Metropolitan Life Insurance v. United States

In this case we are called upon to decide whether a Federal tax lien has priority over the voluntary payments by a mortgagee of local real estate taxes and water charges which accrued after the recording of the Federal lien, although the mortgage under which the local liens were paid was recorded several years before the Federal lien arose.

*357The question is close and not entirely free from doubt. The learned court at Special Term held, in effect, that the payments for local taxes by the plaintiff had priority over the Federal lien.

The chronology of events is neither complicated nor disputed. To…