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U.S. v. ROTHERHAM

No. 87-1796.

836 F.2d 359 (1988)

UNITED STATES of America, Plaintiff-Appellee, v. Patrick D. ROTHERHAM, Defendant-Appellant.

United States Court of Appeals, Seventh Circuit.

Decided January 11, 1988.

Attorney(s) appearing for the Case

Mariann Rogge-Strubing, Pogge-Strubing Law Office, Springfield, Ill., for defendant-appellant.

Kenneth W. Rosenberg, Appellate Sec., Tax Div., Dept. of Justice, Washington, D.C., for plaintiff-appellee.

Before CUMMINGS, CUDAHY and MANION, Circuit Judges.

CUDAHY, Circuit Judge.

This appeal involves competing claims to a 1979 Excalibur automobile. Appellant Patrick Rotherham claims he has a security interest in the car that should have priority over the government's tax liens. The Internal Revenue Service (the "IRS"), not surprisingly, disagrees. The district court found for the government. We affirm.

I.

The factual setting is rather complex. We will only discuss those facts relevant to this appeal...

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