United States v. John R. Blackett

Upon the date this appeal was lodged in this court John R. Blackett was delinquent in the payment of internal revenue to the United States in a sum greater than the total of the two sums of money involved in this case. Liens for the payment of the principal sum with accruing interest, under the provisions of the In ternal Revenue Code §§ 3670, 3671, and 3672, had been perfected between February 6, 1948, and May 4, 1948, and apparently existed in full force and effect up to the date of the lodgment. The record shows no change to date.

Blackett owned and conducted a bar under a California liquor license issued to him, and he carried certain bottled liquor as supply for the bar business.

On June 17, 1949, Cross, Bates & Company, a copartnership, and the individuals of such partnership, to-wit, Thomas G. Cross and Leo K. Bates, Sr., sued Blackett in the Municipal Court of San Diego, California, for an alleged debt, and sued out a writ of attachment. Three days later levy was made on the stock of liquor. Judgment was entered for plaintiff on October 26, 1949, and execution issued the next day. On November 30, 1949, the liquor levied upon was sold for $300.00. Immediately before and…