Banco Popular De Puerto Rico v. United States (In re Reitter Corp.)

OPINION AND ORDER

DANIEL R. DOMINGUEZ, District Judge.

Pending before the Court are two appeals which have been consolidated, as both are intrinsically intertwined. In both cases, appellant Banco Popular de Puerto Rico (“BPPR”) challenges the decision of the bankruptcy court finding that the United States of America through its agency the Internal Revenue Service (the “United States” or the “IRS”), “is the senior lien holder over Debtor’s [Reitter Corporation d/b/a Hospital San Gerardo (hereinafter ‘Reitter’) ] accounts receivable which were generated on or after March 1, 2010.” See Opinion and…