TAX 9900 Lecture Notes - Lecture 6: British Home Stores
Document Summary
Purchaser of security who at the time of purchase did not have actual notice or knowledge of the existence of such lien. Bh(brokerage house) has an inventory of stock. A buys 100 shares of ibm from bh on 3/10/18. Securities, stocks and bonds are super priorities. First in time, first in right has exceptions (super priorities): even though the irs filed nftl, the transferee/purchaser of ppty gets it free/clear of any tax lien. Super priority notice of federal tax lien does not attach to certain t-ferred ppty. Purchaser takes ppty free/clear of any tax lien. Protects 3rd parties, not tp who owes tax. For example, motor vehicles: if you buy a motor vehicle, you take free/clear of any irs lien. But if you owe tax yourself, irs can seize your car. If you have lien filed against you and you sell car to 3rd party, irs cannot go after 3rd party; if after you, irs can take your car.
