United States v. McDermott (1993)

The IRS (creditor) assessed the McDermotts (debtors) for unpaid taxes and created a lien reaching all their current and after-acquired property; Zions First National Bank (creditor) separately obtained a judgment lien against the same property and filed notice of it on July 6. The IRS filed notice of its tax lien on September 9. Only afterward, on September 23, did the McDermotts acquire the specific parcel of real property both creditors were claiming against. The parties agreed the IRS and bank would release their claims on the property itself in exchange for keeping their priority rights in the eventual sale proceeds. The district court and court of appeals ruled the bank's lien had priority, and the government sought Supreme Court review.