Each of said defendants is a local taxing unit of the Commonwealth of Pennsylvania within the jurisdiction of the court, which assert tax liens against the real estate interests of the debtor, Frank A. Maddas, and which maintain that said tax liens have priority over the tax liens of the United States of America.
Action was instituted on April 15, 1947 and the facts are not in dispute, so that the determination herein must relate itself solely to the law.
The taxpayer filed income tax returns for the years 1920, 1921 and 1922, which were false and fraudulent and filed with the intention to evade federal taxes.
On August 10, 1935, the Commissioner of Internal Revenue made jeopardy assessments of income taxes for 1920 to 1922, inclusive, in the total amount of $ 2,570,663.70, including penalties and assessed interest. The assessment list was signed by the Commissioner and was scheduled to and received by the Collector at Pittsburgh, Pennsylvania, on August 12, 1935. Notice and demand were made on August 13, August 24 and September 4, 1935. Notices of tax liens were duly filed by the collector with the clerk of the United States District Court for this District and the Prothonotary of Westmoreland County, on or about July 27 and July 29, 1939.
Prior to July 27 and July 29, 1939, the County of Westmoreland, City of Jeannette and School District of Jeannette levied and assessed real estate taxes for 1939 against the property of the taxpayer in the following face amounts:
County $ 136.75
County Institution District 41.03
Total $ 1189.73
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