Legal Opinion
Sam P. Sgro v. United States
Court of Appeals for the Seventh Circuit
Decided January 15, 1980No. 79-1236PublishedCited by 33 opinions
1Opinion of the Court
HARLINGTON WOOD, Jr., Circuit Judge.
We address the question whether a security agreement that grants a sole shareholder a lien on the assets of a close corporation to secure a note made by the purchasers of his interest is a “commercial transactions financing agreement” within the meaning of section 6323(c) of the Internal Revenue Code, 26 U.S.C. § 6323(c) (1976). The relative priority of that lien and a federal tax lien, upon which the Internal Revenue Service (IRS) has levied, depends on the resolution of this issue.
State law governs the vast majority of conflicts between lienholders…
2Cases cited10 opinions
- United States v. City of New BritainSupreme Court of the United States · 1954
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Whipple v. CommissionerSupreme Court of the United States · 1963
- United States v. GeneresSupreme Court of the United States · 1972
- United States v. Pioneer American InsuranceSupreme Court of the United States · 1963
5 more not listed; retrieve them via the Exa API.
3Cited by33 opinions
- Giotis v. Apollo of the Ozarks, Inc.Court of Appeals for the Seventh Circuit · 1986
- Texas Commerce Bank-Fort Worth, N.A., Plaintiff-Appellee/cross-Appellant v. United States of America, Defendant-Appellant/cross-AppelleeCourt of Appeals for the Fifth Circuit · 1990
- Gehl Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- Wright v. NewmanCourt of Appeals for the Eighth Circuit · 1984
- J.D. Court, Inc., a Corporation v. United States of America, Acting Through the Department of Treasury, Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 1983
28 more not listed; retrieve them via the Exa API.