Attorney Fee Priority Over Tax Liens

§ 6323. Validity and priority against certain persons(a) Purchasers, holders of security interests, mechanic’s lienors, and judgment lien creditorsThe lien imposed by section 6321 shall not be valid as against any purchaser, holder of a security interest, mechanic’s lienor, or judgment lien creditor until notice thereof which meets the requirements of subsection (f) has been filed by the Secretary. (b) Protection for certain interests even though notice filedEven though notice of a lien imposed by section 6321 has been filed, such lien shall not be valid—(1) SecuritiesWith respect to a security (as defined in subsection (h)(4))—(A) as against a purchaser of such security who at the time of purchase did not have actual notice or knowledge of the existence of such lien; and (B) as against a holder of a security interest in such security who, at the time such interest came into existence, did not have actual notice or knowledge of the existence of such lien. (2) Motor vehiclesWith respect to a motor vehicle (as defined in subsection (h)(3)), as against a purchaser of such motor vehicle, if—(A) at the time of the purchase such purchaser did not have actual notice or knowledge of the existence of such lien, and (B) before the purchaser obtains such notice or knowledge, he has acquired possession of such motor vehicle and has not thereafter relinquished possession of such motor vehicle to the seller or his agent. (3) Personal property purchased at retailWith respect to tangible personal property purchased at retail, as against a purchaser in the ordinary course of the seller’s trade or business, unless at the time of such purchase such purchaser intends such purchase to (or knows such purchase will) hinder, evade, or defeat the collection of any tax under this title. (4) Personal property purchased in casual saleWith respect to household goods, personal effects, or other tangible personal property described in section 6334(a) purchased (not for resale) in a casual sale for less than $1,000, as against the purchaser, but only if such purchaser does not have actual notice or knowledge (A) of the existence of such lien, or (B) that this sale is one of a series of sales. (5) Personal property subject to possessory lienWith respect to tangible personal property subject to a lien under local law securing the reasonable price of the repair or improvement of such property, as against a holder of such a lien, if such holder is, and has been, continuously in possession of such property from the time such lien arose. (6) Real property tax and special assessment liensWith respect to real property, as against a holder of a lien upon such property, if such lien is entitled under local law to priority over security interests in such property which are prior in time, and such lien secures payment of—(A) a tax of general application levied by any taxing authority based upon the value of such property;