October 1, 2008

A Primer on Federal Tax Liens, the 45-Day Rule, and Future Advances. Part One of a Two-Part Article

By Francis X. Buckley, Jr. and Nicholas H. Kappas

This article provides a review of the basic principles of federal tax liens and secured transactions under Article 9 of the UCC ("Article 9") and discusses certain issues that arise with respect to the priority of federal tax liens against certain interest holders under the "45-day rule" of the Internal Revenue Code of 1986, as amended (the "Code").

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