First Interstate Bank of Utah, N.A. v. Internal Revenue Service

Olympus Glass, a glazing contractor, defaulted on federal taxes, and the IRS (creditor) filed a tax lien; afterward, Olympus obtained a line-of-credit loan from First Interstate Bank of Utah (creditor) to fund its ongoing performance of existing glazing contracts. When Olympus later filed for bankruptcy, the IRS argued its earlier-filed tax lien had priority over the bank's later loan under the standard first-in-time rule, while the bank argued its loan qualified as a purchase-money security interest entitled to superpriority regardless of timing. The bankruptcy and district courts sided with the IRS, and the bank appealed.