Maryland's federal district court rejected the IRS contention that internal IRS regulations wipe out state recording statutes and the "relation back" principle that gives deeds an effective date prior to actual recording. The "relation back" principle thus operates in Maryland to beat an IRS tax lien that is recorded before a bank deed of trust. The IRS internal regulations cannot trump the unambiguous meaning of the federal statute passed by Congress which clearly incorporates operation of state "relation back" recording statutes.
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