Validity and Priority of Lien Against Mortgagees, Pledgees, Purchasers, and Judgment Creditors (Valid v. Invalid)

ID:
UILC:
CCA_2016032111151814
6323.00-00
Number: 201616010
Release Date: 4/15/2016
From:
Sent: Monday, March 21, 2016 11:15:18 AM
To:
Cc:
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Subject: RE: Non-bankruptcy GL question
On these facts, I think the bank’s priority is limited to the original loan amount. Under
IRC 6323(h)(1), the bank is only deemed to have a “security interest” to the extent the lender “has parted with money or money’s worth.”