The following excerpt is from Southold Sav. Bank v. Finkelstein, 243 N.Y.S.2d 397, 40 Misc.2d 381 (N.Y. Cty. Ct. 1963):
[40 Misc.2d 382] The priority of federal tax liens provided by 26 U.S.C. 6321 as against liens created under State Law, is governed by the common law rule--'the first in time is the first in right' (United States v. New Britain, 347 U.S. 81, 85-86, 74 S.Ct. 367, 371, 98 L.Ed. 520).
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