Nature of the Case
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Facts
On December 8, 1960, Truck Equipment Corp. recovered a judgment against Fornabai. On March 10, 1961, Pak-Mor Manufacturing Co. recovered its judgment against Fornabai. The Government (P) filed a notice of tax liens against Fornabai on April 10, 1961. On May 2, 1962, Fornabai was declared bankrupt, and his realty was sold. The proceeds of the real estate sale were insufficient for full satisfaction of the three liens. The order of the referee in Bankruptcy stated that the two judgment liens were entitled to priority in satisfaction over P's tax liens.
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