American Investment Financial v. United States

MEMORANDUM DECISION GRANTING DEFENDANT’S MOTION FOR PARTIAL SUMMARY JUDGMENT AND DENYING PLAINTIFF’S MOTION FOR PARTIAL SUMMARY JUDGMENT

CASSELL, District Judge.

This priority dispute arises out of an IRS tax lien and a security interest in certain collateral held by American Investment Financial (“AIF”). Both of the IRS and AIF liens extend to payments received by a medical care provider, Nightime Pediatrics (“Nightime”) for medical services provided pursuant to agreements Nigh-time had entered into with various healthcare insurance companies (the “Provider Contracts”). The issue before the…