United States of America v. Susquehanna Bank

Appellee's Brief

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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.

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Published In:

Tax

Reference Info:Appellate Brief | Federal, 4th Circuit, Maryland | United States

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Thomas Valkenet, Young & Valkenet | Attorney Advertising

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