Legal Opinion

The Hartford Provision Company v. United States

Court of Appeals for the Second Circuit

Decided April 17, 1978No. 540, Docket 77-6142PublishedCited by 28 opinions

1Opinion of the Court

*9VAN GRAAFEILAND, Circuit Judge:

In United States v. Security Trust & Savings Bank, 340 U.S. 47, 71 S.Ct. 111, 95 L.Ed. 53 (1950), the Supreme Court held that a United States tax lien was prior in right to an earlier recorded attachment lien where the attaching creditor’s claim had not yet proceeded to judgment. The court said that “[njumerous contingencies might arise that would prevent the attachment lien from ever becoming perfected by a judgment awarded and recorded.” Id. at 50, 71 S.Ct. at 113. The Internal Revenue Service now contends that a tax lien, recorded after judgment is secured by…

2Cases cited26 opinions

  1. United States v. City of New BritainSupreme Court of the United States · 1954
  2. United States v. Security Trust & Savings BankSupreme Court of the United States · 1950
  3. United States v. AcriSupreme Court of the United States · 1955
  4. United States v. Waddill, Holland & Flinn, Inc.Supreme Court of the United States · 1945
  5. United States v. VermontSupreme Court of the United States · 1964

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3Cited by28 opinions

  1. United States v. McCombsCourt of Appeals for the Second Circuit · 1994
  2. UNITED STATES v. McCOMBSCourt of Appeals for the Second Circuit · 1994
  3. Dsi Associates LLC v. United StatesCourt of Appeals for the Second Circuit · 2007
  4. In Re International Banking Corp. B.S.C.United States Bankruptcy Court, S.D. New York · 2010
  5. In Re May Reporting Services, Inc.United States Bankruptcy Court, D. South Dakota · 1990

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