Graham

The United States (hereafter “Government”) commenced this action in the District Court for the Northern District of California, Southern Division, to foreclose alleged Federal tax liens. 26 U.S. C.A. (I.R.C.1939) § 3678. A judgment for the Government establishing liens *921 .and decree of foreclosure and order of sale was entered September 14, 1955. .Appellants appeal from this judgment.

The taxes sought to be collected are ‘Federal income and excess profits taxes for the year 1942 assessed against each •of the Grahams as transferees of the Kincaid Company in the Second District of New York, which assessments were transferred to the Collector of Internal Revenue, San Francisco; withholding and Federal insurance contribution taxes, penalties and interest for the four quarters of the calendar year 1945 and the first three quarters of the calendar year 1946 in the aggregate amount of $542,706.95 against Warren C. Graham and Agnes B. Graham, doing business as Graham Ship Repair Company; and Federal income taxes for the years 1945 -and 1946 against Warren C. Graham and Agnes B. Graham in the amount of $1,-139,375.86. 1 The value of the property sought to be sold by lien foreclosure in…