United States v. Francis Taylor, Mary E. Taylor

RILEY, Circuit Judge.

This case arises out of an April 1996 Northwest Airlines (Northwest) inter-pleader of the United States and Mary Taylor (Mary) to determine whether the Internal Revenue Service (IRS) or Mary has priority and is entitled to the benefits of three Northwest sponsored employee benefits plans. On cross motions for summary judgment, the district court ruled generally for the IRS and against Mary, finding Mary’s right to the plans under a *949Texas domestic relations order (DRO) was subject to a prior federal tax lien. We disagree and reverse.

I. BACKGROUND

As is often the case, the…