Adams, County Treasurer v. O'malley, Collector of Internal Revenue

SANBORN, Circuit Judge.

This is a controversy between the County of Douglas, Nebraska, and the United States over the priorities of their respective tax liens in the bankruptcy proceedings of Empire Contractors, Inc. The Referee in Bankruptcy and the District Court, on review of his order, determined that the liens of the United States for social security and withholding taxes were entitled to priority over the liens of the County for personal property taxes. The trustee in bankruptcy was therefore directed to apply the funds in his hands, which were insufficient to pay the liens in full,…