The United States’ judgment liens had priority over the county’s tax liens, a district court held, granting the government’s motion for summary judgment and ordering a judicial sale of the property. Taxpayers, a married couple, failed to pay federal income taxes and employment taxes for several years. The government obtained judgments against Taxpayers and recorded judgment liens on their property in 2012. The county’s tax liens for unpaid property taxes attached to the property in 2015. The court held that the Federal Debt Collection Procedures Act (FDCPA), not the Federal Tax Lien Act, governed the priority of the government’s judgment ...
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