Legal Opinion
Citizens Co-Op Gin v. United States
Court of Appeals for the Fifth Circuit
Decided June 16, 1970No. 28136PublishedCited by 16 opinions
1Opinion of the Court
GOLDBERG, Circuit Judge:
The Commissioner of Internal Revenue contests an adverse judgment of the court below regarding the relative priority of a federal tax lien. The Commissioner asks us to narrowly construe the Federal Tax Lien Act, ignoring the fact that its very genesis was in generosity. Looking to the Congressional intent underlying the statute, we refuse to subvert its tolerant purpose in such a fashion.
The taxpayers, J. B. and Leola Marion, were indebted to the United States for $37,261.51 in income taxes as a result of a Tax Court judgment entered on March 11, 1968. The United…
2Cases cited14 opinions
- United States v. AcriSupreme Court of the United States · 1955
- United States v. Liverpool & London & Globe InsuranceSupreme Court of the United States · 1955
- United States v. White Bear Brewing Co., Inc. Et Al.Supreme Court of the United States · 1956
- The United States of America v. White Bear Brewing Co., Inc., and Chicago Title and Trust Company as TrusteeCourt of Appeals for the Seventh Circuit · 1955
- Wood v. BarnesCourt of Appeals of Texas · 1967
9 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Aaron Henry v. First National Bank of Clarksdale v. Mississippi Action for Progress, Inc.Court of Appeals for the First Circuit · 1979
- Bray v. CurtisCourt of Appeals of Texas · 1976
- In the Matter of Russell Durwood Daves, Debtor, Republicbank, Lubbock, N.A. v. Russell Durwood DavesCourt of Appeals for the Fifth Circuit · 1985
- United States v. Zac A. Crittenden, Jr., D/B/A Crittenden Tractor CompanyCourt of Appeals for the Fifth Circuit · 1977
- Spring Service Texas, Inc. v. McConnell (In Re McConnell)United States Bankruptcy Court, S.D. Texas · 1989
11 more not listed; retrieve them via the Exa API.