United States v. 3809 Crain Ltd. Partnership

PHILLIPS, Circuit Judge:

This is the second appeal in the government’s continuing attempt to collect the unpaid estate tax liability of Armstead Wayson, who died in 1974. The principal question before us now is whether the district court properly granted summary judgment for the government, determining that its tax lien had priority over a deed of trust held by the First National Bank of Southern Maryland (First National) on estate property sold at foreclosure to the intervening defendant-appellant herein, 3809 Crain Limited Partnership (Crain).1 Having concluded that the district court’s…