Jonathan Paskow, as Trustee v. Calvert Fire Insurance Company, United States of America

GODBOLD, Circuit Judge:

The Algiers Hotel was damaged by fire. The building and some personal property in the building were mortgaged and were covered by insurance. This is a dispute over a portion of the insurance fund relating to personal property. The United States claims the fund by virtue of a tax lien filed against the mortgagor, while the mortgagee claims, first, that the tax lien cannot attach to the fund because the fund is not property belonging to the mortgagor and, second, that even if the tax lien can attach to the fund, he has a security interest in the fund that is valid against…