The Internal Revenue Service appealed a grant of summary judgment favoring Mr. Valkenet's client, Susquehanna Bank. The Maryland bankruptcy court granted the bank's indemnity deed of trust priority over IRS tax liens by operation of Maryland's "relation back" recording statutes. This entitled the bank to take the entire fund created by the sale of the bankrupt's commercial land. The IRS appealed to the US District Court. This is our brief for the Appellee arguing statutory construction governing tax lien priorities.