United States America v. Ray Thomas Gravel Co‪.‬

The main question here is whether a federal tax lien is superior, under the circumstances, to the attorneys fees of an interpleader. The amount of the attorneys fee for the interpleader action has not yet been fixed. The courts below have held that the interpleaders attorneys fee is superior. Because of the federal statute and opinions of the Supreme Court of the United States, this holding cannot stand.