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QUESTION: Does a federal tax lien on a motor vehicle, filed in the office of the clerk of the circuit court pursuant to s. 28.222, F. S., have priority over a security interest in said motor vehicle subsequently filed by a third party with the Department of Highway Safety and Motor Vehicles?

SUMMARY: Section 28.222(3)(e), F. S., authorizes and requires the filing or recordation of notices of federal tax liens with the clerk of the circuit court. Said section applies to federal tax liens on motor vehicles and meets the Internal Revenue Code "one office as designated by state law" requirement…