United States v. Brosnan

WILLSON, District Judge.

In this civil action the United States seeks to enforce liens for unpaid taxes. The controversy arises because admit tedly the tax liens wére junior in point of time to a duly recorded purchase money mortgage on the real property in question. The mortgage has been foreclosed. The defendants, who were the purchasers at the mortgage foreclosure sale, claim that the mortgage foreclosure proceedings divested the unpaid tax liens of the Government. The Government contends that the unpaid tax liens were not divested by the foreclosure sale. The Government is proceeding under…