Legal Opinion
Plymouth Savings Bank v. United States Internal Revenue Service and Massachusetts Department of Revenue
Court of Appeals for the First Circuit
Decided August 12, 1999No. 98-1930PublishedCited by 20 opinions
1Opinion of the Court
CUDAHY, Senior Circuit Judge.
Jordan Hospital (“Hospital”) owed Shirley Dionne (“Dionne”) $75,000. Dionne, in turn, was indebted to the Plymouth Savings Bank (“Bank”) and the Internal Revenue Service (“IRS”), both of which held valid liens on the money the Hospital owed Dionne. The Hospital deposited the money with the district court, and we must now decide who is entitled to it. The problem is simply to determine which of the two liens has priority. We hold that the Bank’s, lien may trump the IRS’s and therefore reverse the district court’s grant of summary judgment in favor of the IRS.
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2Cases cited11 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Glass City Bank v. United StatesSupreme Court of the United States · 1945
- St. Paul Fire and Marine Insurance Company v. Warwick Dyeing CorporationCourt of Appeals for the First Circuit · 1994
- Texas Oil & Gas Corporation v. The United States of America, the Pecos County State BankCourt of Appeals for the Fifth Circuit · 1972
6 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Clockedile v. New Hampshire Department of CorrectionsCourt of Appeals for the First Circuit · 2001
- Evergreen Partnering Group v. Pactiv CorporationCourt of Appeals for the First Circuit · 2013
- Textron Inc. v. Commissioner of IRSCourt of Appeals for the First Circuit · 2003
- Sierra Club v. WagnerCourt of Appeals for the First Circuit · 2009
- Negron-Fuentes v. UPS Supply Chain SolutionsCourt of Appeals for the First Circuit · 2008
15 more not listed; retrieve them via the Exa API.