| 1995 - 704 páginas
...Even though a notice of a lien imposed by section 6321 is filed in accordance with §301.6323(f)-1, the lien is not valid with respect to a security interest...definitions of the terms "security interest" and "tax Hen filing." For purposes of this section, a judgment lien is a lien held by a judgment lien creditor... | |
| 1988 - 600 páginas
...Even though a notice of a lien imposed by section 6321 is filed in accordance with § 301.6323(f)1, the lien is not valid with respect to a security interest...to such an agreement. See paragraphs (a) and (e) of § 301.6323(h)-1 for general definitions of the terms "security interest" and "tax lien filing." For... | |
| 1999 - 780 páginas
...not valid with respect to Y's December 6, 1971, purchase of N's accounts receivable. [TD 7429, 41 FR 35503, Aug. 23. 1976] $ 301.6323(c)-2 Protection for...against a judgment lien arising, as of the time of tax Hen filing, out of an unsecured obligation. For purposes of this section, it is immaterial that the... | |
| 1988 - 566 páginas
...the tax lien filing, (2) Is in qualified property covered by the terms of a commercial transactions financing agreement entered into before the tax lien...against a judgment lien arising, as of the time of the tax lien filing, out of an unsecured obligation. See paragraphs (a) and (e) of § 301.6323(h)-1... | |
| 1992 - 616 páginas
...cash disbursements to finance the construction of real property, and because B's security interest is protected, under local law, against a judgment...of tax lien filing out of an unsecured obligation, B's security interest has priority over the tax lien. 26 CFR Ch. I (4-1-92 Edition) Example 2. (i)... | |
| 1996 - 792 páginas
...disbursements to finance a contract to demolish real property, and because D's security Interest is valid under local law against a judgment lien arising as...of tax lien filing out of an unsecured obligation, the tax lien Is not valid with respect to D's security interest In the proceeds of the demolition contract.... | |
| 1998 - 750 páginas
...of a real property construction or improvement financing agreement entered into before the tax Hen filing, and (3) Is protected under local law against a judgment lien arising, as of the time of tax Hen filing, out of an unsecured obligation. For purposes of this section, it is immaterial that the... | |
| 2000 - 816 páginas
...the taxpayer in the construction project if its security interest in the tangible personal property is protected under local law against a Judgment lien arising, as of the time the tax lien was filed, out of an unsecured obligation. (3) Examples. This section may be illustrated... | |
| 1999 - 782 páginas
...disbursements to finance a contract to demolish real property, and because D's security interest is valid under local law against a judgment lien arising as of the time of tax Hen filing out of an unsecured obligation, the tax lien is not valid with respect to D's security interest... | |
| United States. Internal Revenue Service - 1967 - 1388 páginas
...construction or improvement financing agreement, or (HI) an obligatory disbursement agreement, and (B) is protected under local law against a judgment lien...of tax lien filing, out of an unsecured obligation. (2) COMMERCIAL TRANSACTIONS FINANCING AGREEMENT. — For purposes of this subsection — (A) DEFINITION.... | |
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