Citizens State Bank v. United States of America, on Behalf of Its Internal Revenue Services Liberty National Bank

Plaintiff Citizens State Bank (“CSB”) appeals the district court’s declaratory judgment finding that a federal tax lien is superior to CSB’s lien against funds remaining in an escrow account. For the reasons that follow, we affirm.

I

This action arises out of a lien priority dispute between CSB and the United States, on behalf of the Internal Revenue Service (“IRS”), as to distribution of the proceeds from real estate formerly owned by J. Elliott Haney, Jr. and Dorothy D. Haney.

The Haneys once owned real estate located at 4103 Fairfax Court in Owensboro, Kentucky. Pursuant to two notes secured…