Davis v. Mississippi State Tax Commission

CHANDLER, Justice,

for the Court:

¶ 1. In this appeal, the Internal Revenue Service of the United States (IRS) and the Mississippi State Tax Commission (Commission) both claim priority interests in the funds of an insolvent estate. The Chancery Court of Lee County found that the Commission’s claim had priority because the Commission had filed notices of tax lien and qualified as a “judgment lien creditor” under 26 U.S.C. § 6323. We find that, because the notices of tax lien were not judgments of a court of record as required by federal law, the Commission did not qualify as a “judgment lien…