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  5. 665 N.E.2d 534 (1996)
 

FARMERS STATE BANK v. NEESE

No. 4-95-0509.

665 N.E.2d 534 (1996)

FARMERS STATE BANK, Pittsfield, Illinois, a State Chartered Corporation, Plaintiff-Appellant, v. Thomas D. NEESE, Susan C. Neese, State of Illinois, and United States of America, Department of the Treasury, Internal Revenue Service, Defendants-Appellees, and Walter V. Wade, Wilma F. Wade, Inez Neese Trust, Dean Neese, Trustee, First Bank, Pittsfield, Illinois, Unknown Owners and Nonrecord Claimants, Defendants.

Appellate Court of Illinois, Fourth District.

Decided May 9, 1996.

Attorney(s) appearing for the Case

John H. Germeraad, argued, Sturm and Germeraad, Springfield, for Farmers State Bank.

Elizabeth L. Collins, John Duncan, argued, Assistant U.S. Attorneys, Office of U.S. Attorney, Springfield, for United States Of America.

John M. Myers, Rabin, Myers & Hanken, P.C., Springfield, for Thomas Neese and Susan Neese.

Justice GARMAN delivered the opinion of the court:

This appeal involves the relative priority of the rights of the Internal Revenue Service of the United States (IRS) and Farmers State Bank (bank) to the proceeds from a foreclosure sale of property which a debtor was purchasing under a real estate installment contract. The trial court gave the IRS lien for unpaid tax priority over the bank's interest as assignee of the buyer's rights as security for a loan. We affirm...

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