Byron White

“ Both New Britain and Buffalo Savings Bank prefer the federal lien even though the mortgagee's interest in the proceeds will be reduced by later-arising local taxes having priority under state law over the mortgagee. The attorney's services, moreover, were rendered for the benefit of the mortgagee to protect his interest in the property, and the United States, holding an adverse interest, received no such benefit from them that its interest is to be charged therefor. ”

“ Alfred J. Anderson shared thereafter on his mechanic's lien and the United States took last. The property was sold and proceeds were received which satisfied all claims except $3,615.28 of the federal tax liens. [3] The United States appealed to the Supreme Court of Arkansas asserting that it was entitled to priority over the attorney's fees, [4] and that $1,250 more should have been applied to reduce the unpaid federal taxes. [5] With one judge dissenting, the Arkansas court rejected that contention and sustained the superiority of the claim for the attorney's fee. ”

“ An attempt to enforce such liens on recorded notice would in many cases impair the negotiability of securities and seriously interfere with business transactions. The adoption of the amendment will remove an existing hardship without causing any undue loss of revenue.' H.R.Rep. ”