United States v. Hoffman

CORRECTED OPINION

HOWARD, Judge.

The United States of America appeals from the dismissal of its claim to $63,500, which sum was interpled by Title Security Agency of Arizona (Title Security). The United States claims this sum based upon tax liens against Gerald E. Kaphing. Ap-pellees as allegedly secured creditors also claim an interest in this sum.

FACTS

In May 1976, Kaphing sold certain real property to Western Palms Associates (Western Palms), Classic Development Corporation (Classic), and others. As part of the transaction, Kaphing received a promissory note executed by Western Palms, secured…