J. N. Randall, Sr., and American International Telephone Co. v. H. Nakashima & Co., Ltd., United States of America

GOLDBERG, Circuit Judge:

In this case we re-enter the tortured meanderings of federal tax lien law, intersected now by the somewhat smoother byway of the Uniform Commercial Code. See Texas Oil & Gas Corporation v. United States, 466 F.2d 1040, 1041 (5th Cir. 1972), cert. denied, 410 U.S. 929, 93 S.Ct. 1367, 35 L.Ed.2d 591 (1973). We must decide between the competing claims to a PBX line telephone system asserted by the government, pursuant to duly filed federal tax liens, and the party to whom the delinquent taxpayer subsequently conveyed his rights in the telephone equipment. The question…