United States v. Estate of Romani
United States Supreme Court
523 U.S. 517 (1998)
Romani Industries (RI) perfected a judgment lien against Francis Romani's Pennsylvania property by filing its judgment with the county clerk. Only afterward did the IRS file notice of federal tax liens against the same property for Romani's unpaid taxes. After Romani died, his estate (defendant) sought court approval to transfer the sole remaining property to RI to satisfy RI's earlier lien. The federal government objected, invoking the separate federal priority statute, which it argued entitled it to be paid first from a debtor's estate regardless of the Federal Tax Lien Act (FTLA). Pennsylvania's courts sided with the estate and RI, and the government sought Supreme Court review.
Whether the federal priority statute gives the government an unqualified right to be paid first out of a debtor's estate, ahead of an earlier perfected judgment lien.