Manalis Finance Co., a Co-Partnership v. United States
Court of Appeals for the Ninth Circuit
1Opinion of the Court
EUGENE A. WRIGHT, Circuit Judge:
This appeal involves conflicting claims to Medical funds owed Manchester Community Hospital. The dispute is between Manalis, a lender holding a perfected security interest in the hospital’s accounts receivable, and the United States, which claims the money under a federal tax lien resulting from the hospital’s failure to pay federal employment taxes.
The government appeals from a decision that, under I.R.C. § 6323, the security interest had priority over the federal tax lien. It contends that the district court erred in its interpretation of § 14115.5 of the…
2Cases cited12 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Bernhardt v. Polygraphic Co. of America, Inc.Supreme Court of the United States · 1956
- Slodov v. United StatesSupreme Court of the United States · 1978
- Fidelity Union Trust Co. v. FieldSupreme Court of the United States · 1941
- Billie J. Preaseau v. The Prudential Insurance Company of AmericaCourt of Appeals for the Ninth Circuit · 1979
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3Cited by21 opinions
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- Dionisio Sainz Gonzalez v. Banco De Santander-Puerto Rico, Dionisio Sainz Gonzalez v. Banco De Santander-Puerto RicoCourt of Appeals for the First Circuit · 1991
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