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NOTES 771 Tax Lawyer, Vol. 53, No. 3 NOTE A FRAMEWORK FOR DETERMINING PRIORITY OF TAX LIENS PURSUANT TO SECTION 6323: AMATO V. UNITED STATES In Amato v. United States,1 the U.S. District Court for the District of Idaho held that a real estate purchaser’s interest in property had priority over a prior perfected judgment lien creditor’s interest and the federal government’s tax lien. As a matter of Idaho law, the real estate contract was a valid agreement based on the doctrine of partial...