Prodigy Centers/Atlanta No. 1 L.P. v. T-C Associates, Ltd.

In this ease, the government and T-C Associates (“TCA”) assert liens on a distribution to Prodigy Child Development Centers (“PCDC”) from a limited partnership. Although TCA obtained a judgment against PCDC before the government recorded its tax lien in 1993, the government argues that TCA’s judgment lien did not attach to PCDC’s partnership interest until TCA obtained a charging order in 1994, because PCDC’s partnership interest was a “chose in action.” After determining that the issue of whether the partnership interest was a chose in action was dispositive of this appeal but unsettled as a…