WILSON, EXECUTOR, ET AL.

v.

SIMLER

Citator

Cited By

• United States v. Acri, 348 U.S. 211 (U.S. 1955)
  …ty between an attachment lien and the liens of the United States for unpaid taxes. The District Court found the attachment [*212] lien prior to the liens of the United States, and the Court of Appeals affirmed without opinion. We granted certiorari, 347 U. S. 973. On August 11, 1948, the United--States filed suit in the District Court for the Northern District of Ohio to collect unpaid income taxes for the years 1942-1946 against one Acri and his wife. Acri was at the time in the penitentiary for the murder…
• United States v. Liverpool & London & Globe Ins. Co., Ltd., 348 U.S. 215 (U.S. 1955)
  …urt held the lien of the garnisher superior to the liens of the United States for taxes and allowed the garnishee $500 for attorney’s fees. 107 F. Supp. 405. The Court of Appeals affirmed, one judge dissenting. 209 F. 2d 684. We granted certiorari, 347 U. S. 973. [*217] The question of priorities is identical with that of United States v. Acri, ante, p. 211, and United States v. Security Trust Co., 340 U. S. 47. On the authority of those cases we hold the tax liens of the United States superior to the lien…
• MacAtee, Inc. v. United States, 214 F.2d 717 (5th Cir. 1954)
  …w been assessed may not be conclusive that they are owing, and, before a decree of foreclosure, the taxpayer is entitled to-his day in court. United States v. Acri, D.C., 109 F.Supp. 943, 944, affirmed 6 Cir., 209 F. 2d 258, certiorari granted 1954, 347 U.S. 973, 74 S.Ct. 784. See 33 Am.Jur., Liens, Section 47. 26 U.S.C.A. § 3678(b)5 seems to us to make the taxpayer an indispensable party to a civil action to enforce a lien on his. [*721] property. While the taxpayer’s absence is not complained of by either…

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