United States v. Park Towers, Inc., Charles I. Denechaud, III and the Roman Catholic Church of Archdiocese of New Orleans

REAVLEY, Circuit Judge:

The United States initiated suit to reduce its tax assessments against Park Towers, Inc. (“Park Towers”) to judgment and to foreclose on federal tax liens against that corporation’s interest in the assets of the Park Tower Apartments Partnership (“The Louisiana Partnership”). The Archdiocese of New Orleans claimed to be a creditor of the Louisiana Partnership, however, and thus to enjoy priority over the United States, a creditor only of the general partner Park Towers. The district court held that the United States was the primary lienholder entitled to Park Towers’…