Western National Bank v. United States

PATRICK E. HIGGINBOTHAM, Circuit Judge:

The United States and the State of Texas both claim the same bank account to satisfy tax liabilities. We affirm the district court’s grant of summary judgment for the federal government, persuaded that the federal lien attached to the account before the state’s claim arose.

I

This case stems from a secured transaction among oil companies. In August 1991, 3-B Rattlesnake Refining Limited and 3-B Rattlesnake Refining Corporation executed a UCC-1 financing statement in favor of Enron Oil Trading and Transportation Company, which was filed with the state on…