J.D. Court, Inc., a Corporation v. United States of America, Acting Through the Department of Treasury, Internal Revenue Service

COFFEY, Circuit Judge.

This appeal involves a determination of the respective priority between a federal tax lien on a taxpayer’s accounts receivable and a private individual’s security interest in the same accounts receivable. The district court granted summary judgment in favor of the government finding that the federal tax lien was entitled to priority in all of the taxpayer’s accounts receivable arising more than 45 days after the Internal Revenue Service first filed notice of its tax lien. We affirm.

I

On June 20, 1977, the Director of the Illinois Department of Public Aid certified the…