Legal Opinion

WPG, Inc. v. Internal Revenue Service (In re WPG, Inc.)

United States Bankruptcy Court, District of Columbia

Decided July 12, 2001No. Bankruptcy No. 99-02150; Adversary No. 00-10058Published

1Opinion of the Court

DECISION GRANTING DISTRICT OF COLUMBIA’S MOTION FOR SUMMARY JUDGMENT

S. MARTIN TEEL, Jr., Bankruptcy Judge.

This is a dispute between the District of Columbia and the Internal Revenue Service (“IRS”) regarding which of those two entities’ tax liens take priority to funds held by the debtor for distribution in accordance with nonbankruptcy law. In claiming priority for its sales tax liens, the District relies upon a congressional enactment now embodied in D.C.Code Ann. § 47-2012 (1997 Repl.) (which the court will refer to as “§ 2012”). In claiming priority for its federal tax liens, the IRS…

2Cases cited5 opinions

  1. Paul D. Pearlstein, Trustee for Sardis, Inc. v. U.S. Small Business Administration. Appeal of District of Columbia GovernmentCourt of Appeals for the D.C. Circuit · 1983
  2. Malakoff v. WashingtonDistrict of Columbia Court of Appeals · 1981
  3. United States v. Harry Saidman, Trustee, Lobel Enterprises, Inc.Court of Appeals for the D.C. Circuit · 1956
  4. District of Columbia v. Samuel M. Greenbaum, Trustee in BankruptcyCourt of Appeals for the D.C. Circuit · 1955
  5. United States v. District of Columbia (In Re Davis Perry Enterprises, Inc.)District Court, District of Columbia · 1989

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