Federal Tax Liens: A Guide to the Priority System of Section 6323 of the Internal Revenue Codea weaker priority and that the choateness test of the tax lien statute was less stringent than Halprinthen borrowed from a finance company in order to meet his payroll and irrevocably assignedto the...
interest in the cause of action that was protected under Arkansas law as against a subsequently acquired judgment lien arising out of an unsecured obligation and therefore was entitled to priority against the United States pursuant to section 6323(a) and (h) (1) of the Internal Revenue Code. ...