United States v. Estate of Romani

Summary

The United States Supreme Court held that the federal priority statute, 31 U.S.C. § 3713(a), did not displace an antecedent, perfected state-law judgment lien on real property when the Government sought payment of delinquent taxes from an insolvent estate. The Court harmonized § 3713 with the more specific Federal Tax Lien Act of 1966 and concluded that the Government's tax liens were not valid against the judgment creditor's earlier lien under 26 U.S.C. § 6323(a). The judgment of the Supreme Court of Pennsylvania was affirmed.

Holdings

1. 31 U.S.C. § 3713(a) does not give the United States priority over an antecedent, perfected judgment lien on real property when the Federal Tax Lien Act provides that the federal tax lien is not valid against that judgment lien creditor.
2. The proper inquiry is how to harmonize the two statutes, and the Tax Lien Act controls when the Government claims a preference against a judgment lien covered by § 6323(a).

Questions Presented

1. Whether 31 U.S.C. § 3713(a) requires a federal tax claim to take priority over an antecedent, perfected judgment lien on real property in an insolvent decedent's estate.
2. Whether the Federal Tax Lien Act of 1966, particularly 26 U.S.C. § 6323(a), governs the priority of the Government's tax lien against a judgment creditor whose lien was perfected before notice of the federal tax lien was filed.

Disposition

affirmed