American Trust v. American Community Mutual Insurance

OPINION

KENNEDY, Circuit Judge.

Defendant Edgar F. Bradley, II, appeals the District Court’s order granting summary judgment in favor of the United States in these consolidated breach of contract and interpleader actions. In its complaint in the interpleader action, the United States sought enforcement of tax liens against insurance sales commissions attributable to defendant. The District Court held that the Government had valid tax liens under 26 U.S.C. § 6321 and that these liens gave the United States the first priority claim to the commissions. On appeal, defendant contends he is entitled…