In Sunz Ins. Co. v. Internal Revenue Service (In re Payroll Management, Inc.), 125 F.4th 1035 (11th Cir. 2025), the United States Court of Appeals for the Eleventh Circuit held that a debtor’s claim for economic damages qualified as a “commercial tort claim” under Article 9 of the Uniform Commercial Code at the time the IRS’s tax lien attached to the claim and was perfected. As a result, the IRS’s lien had priority over a competing lienholder’s claim.
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