United States v. Liverpool & London Ins. Co., Ltd., 348 U.S. 215 (1955)

United States v. Liverpool & London Ins. Co., Ltd.


No. 34


Argued November 16, 1954
Decided January 10, 1955
348 U.S. 215

CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE FIFTH CIRCUIT

Syllabus

1. Tax liens of the United States are entitled to priority over a Texas garnishment lien where the federal tax liens were recorded subsequent to the date of the garnishment lien, but prior to the date the garnisher obtained judgment. United States v. Acri, ante, p. 211; United States v. Security Trust Co., 340 U.S. 47. Pp. 215-217.

2. The garnishment lien in this case not being prior to the federal tax liens, attorney’s fees allowed to the garnishee under Texas law were not prior to the federal tax liens, and authorization of their payment prior to the federal tax liens was error. P. 217. 209 F.2d 684 reversed.