The Shawnee State Bank v. United States

The United States appeals from a judgment of the District Court granting priority to a lien of the Shawnee State Bank (Shawnee Bank) over federal tax liens. In dispute is the right to an amount representing certain accounts receivable acquired by the common debtor of both lienholders more than forty-five days after the filing of notice of the federal tax liens. The United States contends that the District Court incorrectly applied provisions of the Internal Revenue Code of 1954, 26 U.S.C. §§ 6322 and 6323(c), and that Shawnee Bank consequently was awarded $5,433.15, plus interest from 1977,…