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PLYMOUTH SAVINGS BANK v. U.S. I.R.S.

No. 98-1930.

187 F.3d 203 (1999)

PLYMOUTH SAVINGS BANK, Plaintiff, Appellant, v. UNITED STATES INTERNAL REVENUE SERVICE and Massachusetts Department of Revenue, Defendants, Appellees.

United States Court of Appeals, First Circuit.

Decided August 12, 1999.

Attorney(s) appearing for the Case

Howard M. Brown, with whom Bartlett, Hackett, Feinberg, Gentilli, Liston, Brown & Phalen, P.C., was on brief, for appellant.

William S. Estabrook, Attorney, Tax Division, Department of Justice, with whom Loretta C. Argrett, Assistant Attorney General, Donald K. Stern, United States Attorney, and Annette M. Wietecha, Attorney, Tax Division, Department of Justice, were on brief, for appellees.

Before SELYA, Circuit Judge, CUDAHY, Senior Circuit Judge, and STAHL, Circuit Judge.

CUDAHY, Senior Circuit Judge.

Jordan Hospital ("Hospital") owed Shirley Dionne ("Dionne") $75,000. Dionne, in turn, was indebted to the Plymouth Savings Bank ("Bank") and the Internal Revenue Service ("IRS"), both of which held valid liens on the money the Hospital owed Dionne. The Hospital deposited the money with the district court, and we must now decide who is entitled to it. The problem is simply to determine which of...

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