United States v. One 1985 Cadillac Seville, and Approximately $434,097.00 in United States Currency, and Michael Miroyan, Claimant-Appellant

BEEZER, Circuit Judge:

Claimant-appellant Michael Miroyan appeals the district court’s order of summary judgment, and denial of his motion for declaratory judgment, forfeiting United States currency and an automobile to the United States under 21 U.S.C. § 881 (1982) for involvement with controlled substances. Miroyan argues that an Internal Revenue Service (“IRS”) lien on the property at is sue represents a prior equitable interest of the IRS in the res that is superior to any claim unperfected as of the date of lien. He attempts to assert the lien priority. He also objects to the forfeiture…