In Re Frank

PATTERSON, District Judge.

The government filed claim against a bankrupt estate for $536.74 and interest, for tax liability under the Social Security Act, 42 U.S.C.A. § 301 et seq. The trustee in bankruptcy conceded that the claim was entitled to the priority given to taxes by section 64b of the Bankruptcy Act, 11 U.S.C.A. § 104(b). But the government demanded a better position for part of the claim. It asserted that to the extent of $96.23, the amount withheld by the bankrupt from her employees as their tax, there was a trust or lien attaching to the entire assets of the estate. The $96.23…