Mr. Justice Frankfurter, whom Mr. Justice Reed joins, dissenting. I cannot agree with the opinion of the Court insofar as it supposes that § 3672 of the Internal Revenue Code is to be read as requiring that certain procedures — -and the same procedures — be complied with in each State before a creditor becomes the magic “judgment creditor.” Section 3672 gives the United States priority over other creditors but n…
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