Court of Appeals for the Fifth Circuit May 30, 1990, 89-4710 (Metropolitan National Bank, James M. Oberlies and Robert E. Ryan v. United States)

E. GRADY JOLLY, Circuit Judge:

The United States appeals from the district court’s judgment holding that the United States’ perfected tax lien, filed against three parcels of real property owned by the taxpayer, Weaver & Sons, Inc., was not entitled to priority over the interests claimed in the property by the appellees, Metropolitan National Bank (the “Bank”), James M. Oberlies, and Robert E.