United States v. Kensington Shipyard & Drydock Corp.

McLAUGHLIN, Circuit Judge.

This appeal is from an order denying appellant’s motion to dismiss the government’s action under Section 3678 of the Internal Revenue Code, 26 U.S.C.A.Int. Rev.Code, § 3678, 1 to enforce the tax lien of the United States for over $2,000,000 against Kensington Shipyard and Drydock Corporation, a Pennsylvania corporation, and its parent company, Aerodynamic Research Corporation.

Aerodynamic, chartered as a non-business corporation of the District of Columbia, was actually a holding company for several business concerns, including Kensington. Federal tax liens against…