A lender holding $1 Million lien on bankrupt's real property sued for lien priority over approximately $200,000 in IRS liens attaching to the same property. The parties filed cross-motions for summary judgment, based on very different interpretations of Maryland's recording statutes, and the IRS' interpretation of federal regulations and statutes.

After supplemental briefing and oral argument, Judge Gordon granted summary judgment in favor of Susquehanna Bank, declaring it's lien to be superior to that of the IRS. Because the real property was sold, this entitles the lender to receive the entire fund, net of the costs of sale. The parties await Judge Gordon's executed order, and the IRS' decision to appeal.