Oxford Distributing Co. v. Famous Robert's Inc.

Tbe problem presented by tbis case is whether tbe lien created by a judgment creditor’s proceeding supplementary to execution or tbe lien of tbe United States for unpaid taxes attaches first to a refund from tbe State Comptroller on a surrendered liquor license. Tbe court at Special Term has held that tbe judgment creditor gets priority; we think priority goes to tbe Government.

A blanket lien is created by a Federal statute, cast in tbe broadest terms, in favor of tbe United States for unpaid taxes. Such a lien exists upon ‘ ‘ all property ’ ’ and ‘ ‘ rights to property” of tbe taxpayer.…