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Судебные дела / Зарубежная практика  / UNITED STATES of America, Appellee, v. Francis TAYLOR, Defendant, Mary E. Taylor, Appellant., United States Court of Appeals, Eighth Circuit., 338 F.3d 947, Nos. 01-2874, 01-3872., July 31, 2003

UNITED STATES of America, Appellee, v. Francis TAYLOR, Defendant, Mary E. Taylor, Appellant., United States Court of Appeals, Eighth Circuit., 338 F.3d 947, Nos. 01-2874, 01-3872., July 31, 2003

24.06.2008  

UNITED STATES of America, Appellee, v. Francis TAYLOR, Defendant, Mary E. Taylor, Appellant.

United States Court of Appeals, Eighth Circuit.

338 F.3d 947

Nos. 01-2874, 01-3872.

July 31, 2003

Submitted: Jan. 14, 2003.

Filed: July 31, 2003.

Peter D. Gray, argued, Minneapolis, MN, for appellant.

Marion E.M. Erickson, Washington, DC (Eileen J. O'Connor, Teresa E. McLaugh╜lin, on the brief), for appellee.

Before LOKEN, BYE, and RILEY, Circuit Judges.

RILEY, Circuit Judge.

This case arises out of an April 1996 Northwest Airlines (Northwest) inter╜pleader of the United States and Mary Taylor (Mary) to determine whether the Internal Revenue Service (IRS) or Mary has priority and is entitled to the benefits of three Northwest sponsored employee benefits plans. On cross motions for sum╜mary judgment, the district court ruled generally for the IRS and against Mary, finding Mary's right to the plans under a Texas domestic relations order (DRO) was subject to a prior federal tax lien. We disagree and reverse.

I. BACKGROUND

As is often the case, the sequence of events is critical. Francis Taylor (Francis) worked as a pilot for Northwest from 1966 to 1994. During his employment, Francis participated in a retirement plan, a stock plan, and a savings plan administered by Northwest under ERISA. 1 Francis retired from Northwest in September 1994, at which time he filed in a Texas state court for divorce from Mary, his wife of more than thirty years. The following month, in October 1994, a tax court concluded that Francis had not filed tax returns from 1981 through 1985. On May 1, 1995, the IRS assessed deficiencies totaling approxi╜mately $984,310 (including penalties and interest) for those tax years. On July 28, 1995, the Texas court entered a divorce decree and approved a marital settlement agreement. The agreement provided that "to settle all obligations of the marriage," Mary would receive a 90 percent interest in Francis's Northwest employee benefits proceeds (plan proceeds). Also in July, the court entered a purported qualified domestic relations order (QDRO), direct╜ing the plan administrator to distribute Mary's interest in the plan proceeds di╜rectly to her. The Texas court, in the July order, retained jurisdiction to amend or reform the order as necessary to conform with plan requirements and qualify as a QDRO.

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1. Employee Retirement Income Security Act of 1974 (ERISA), as amended, 29 U.S.C. ╖╖ 1001-1461 (2000).

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In October 1995, Northwest informed Mary and Francis that the July DRO did not qualify as a QDRO. In December 1995, the IRS filed a lien against the plan pro╜ceeds in Texas, where Francis claimed he resided at the time of the divorce, and where the DRO issued. In October 1996, the IRS filed another lien in Minnesota, where the plans were administered. Meanwhile, Mary and Francis attempted to correct the DRO's identified deficien╜cies. Among other things, the order (1) did not specify the period to which it ap╜plied; (2) did not address how to treat amounts accrued, but had not yet been credited to the account; and (3) would have required Northwest to make an extra payment. Twice the Texas court, at Mary's request, reformed the DRO to ad╜dress Northwest's concerns. Northwest finally pronounced the DRO a QDRO in January 1997.

The district court dismissed Northwest from the interpleader action, and the IRS and Mary were left to determine who was entitled to the plan proceeds. The IRS claimed its interest in the plan proceeds was first in time, while Mary argued her interest had priority because she was both a "judgment lien creditor" and a "purchas╜er" under 26 U.S.C. ╖ 6323(a), 2 a statute that in certain situations requires the IRS to file notice of its lien to obtain priority.

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2. 26 U.S.C. ╖ 6323(a) states: "Purchasers, holders of security interests, mechanic's lien╜ors, and judgment lien creditors. The 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 [of the Treasury]."

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The district court concluded Mary was neither a purchaser nor a judgment lien creditor under section 6323(a). Specifical╜ly, the court determined Mary was not a purchaser because her consideration was not "adequate and full," as defined in 26 C.F.R. ╖ 301.6323(h)-1(f)(3) (2001) (consid╜eration must have reasonable relationship to true value of interest in acquired prop╜erty). Further, the district court found Mary was not a judgment lien creditor because there was no evidence she had perfected her lien by executing the judg╜ment as required under Texas law. Because Mary was not entitled to the protec╜tions of section 6323, the district court held the IRS tax liens assessed on May 1, 1995, became effective against Mary as of that date and were first in time and entitled to priority.

On appeal, Mary argues: (1) the Texas divorce court had exclusive jurisdiction over this dispute; thus, there was no fed╜eral question and the interpleader action was not proper; (2) under Texas communi╜ty property law, Mary had substantial property rights in the plan proceeds even before the divorce; (3) she was a purchas╜er under section 6323(a); and (4) she was a judgment lien creditor under section 6323(a).

II. DISCUSSION

This court reviews de novo the district court's grant of summary judg╜ment. Mayberry v. United States, 151 F.3d 855, 858 (8th Cir.1998). Initially, we reject Mary's first two arguments: (1) fed╜eral jurisdiction does exist, see 29 U.S.C. ╖ 1132(a)(3) (civil action may be brought by fiduciary to enjoin violations of ERISA plan, or to obtain appropriate equitable relief); and (2) Texas community property law does not vest her with an interest in the plan proceeds. See 29 U.S.C. ╖ 1144(a) (ERISA supersedes state law insofar as such law relates to ERISA-governed plans); Boggs v. Boggs, 520 U.S. 833, 850, 117 S.Ct. 1754, 138 L.Ed.2d 45 (1997) (QDRO provisions define scope of nonparticipant spouse's community proper╜ty interest in pension plans).

We turn next to whether Mary became a judgment lien creditor under section 6323(a) within sufficient time to have priority over the IRS. 3 An IRS lien attaches automatically on the date a penal╜ty is assessed, 26 U.S.C. ╖ 6322 (lien arises at time of assessment), and is en╜forceable as of that date against creditors except any "purchaser," "holder of security interest," "mechanic's .lienor," or "judg╜ment lien creditor," within the meaning of section 6323(a). If the creditor falls into one of these categories, then the IRS must provide adequate notice to establish the priority of its lien. See 26 U.S.C. ╖ 6323(a); Rodeck v. United States, 697 F.Supp. 1508, 1511 (D.Minn.1988) (as to ╖ 6323(a) creditors, tax lien will have pri╜ority only if notice has been filed in accor╜dance with ╖ 6323(f)).

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3. The IRS has authority to proceed against Francis's interest in any ERISA plan benefits and "is not constrained by ERISA's anti-alien╜ation provision." In re McIntyre , 222 F.3d 655, 660 (9th Cir.2000). After the DRO, Francis effectively no longer has any owner╜ship interest in Mary's 90 percent share of the Northwest ERISA plans.

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A Treasury Regulation defines "judg╜ment lien creditor" as follows:

... a person who has obtained a valid judgment, in a court of record and of competent jurisdiction, for the recovery of specifically designated property or for a certain sum of money. In the case of a judgment for the recovery of a certain sum of money, a judgment lien creditor is a person who has perfected a lien under the judgment on the property in╜volved. A judgment lien is not perfect╜ed until the identity of the lienor, the property subject to the lien, and the amount of the lien are established. Ac╜cordingly, a judgment lien does not in╜clude an attachment or garnishment lien until the lien has ripened into judgment, even though under local law the lien of the judgment relates back to an earlier date.

. . .

If under local law levy or seizure is necessary before a judgment lien be╜comes effective against third parties ac╜quiring liens on personal property, then a judgment lien under such local law is not perfected until levy or seizure of the personal property involved.

26 C.F.R. ╖ 301.6323(h)-1(g).

A state law created lien's priority depends on when it attaches and becomes choate, and federal law will determine when the lien has acquired sufficient sub╜stance and becomes so perfected as to defeat a later federal tax lien. United States v. Pioneer Am, Ins. Co., 374 U.S. 84, 88, 83 S.Ct. 1651, 10 L.Ed.2d 770 (1963). Liens are perfected, under the federal rule, when there is nothing more to be done to have a choate lien, that is, "when the identity of the lienowner, the property subject to the lien, and the amount of the lien are established." Id . at 89, 83 S.Ct. 1651 (citations omitted). Here, Mary obtained a valid judgment from a Texas divorce court for 90 percent of Francis's plan proceeds creating an ex╜clusive property interest in the plan pro╜ceeds for Mary. On the date the Texas court granted the DRO, Mary's identity was clear, the subject property was identi╜fied, and the amount (90 percent) was fixed.

Mary was not required to comply with any state law requirements for purposes of establishing lien priority over the IRS's interest in the plan proceeds. ERISA pro╜vides a mechanism for enforcing QDROs, and this mechanism supersedes any con╜trary state law. See U.S. Constitution art. VI, cl. 2, Heart of Am. Grain Inspection Serv., Inc. v. Mo. Dep't of Agric., 123 F.3d 1098, 1103 (8th Cir.1997) (under Suprema╜cy Clause, federal laws are supreme law of land and may preempt state law); cf. Chevron U.S.A. Inc. v. Natural Res. Def. Council. Inc., 467 U.S. 837, 843-44, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984) (agencies may elucidate, through regulations, specif╜ic provisions of statutes that agencies ad╜minister). Specifically, 29 U.S.C. ╖ 1056(d) provides for alienation of pen╜sion plan benefits in accordance with a QDRO, and gives plan administrators or courts eighteen months to determine whether a DRO qualifies as a QDRO, di╜recting the plan administrator to segregate the amounts in question during that peri╜od. See 29 U.S.C. ╖ 1056(d)(3)(H). 4

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4. pension benefit plans are distinguishable from welfare benefit plans, which do not pro╜vide an enforcement mechanism. See Mackey v. Lanier Collection Agency & Serv., Inc., 486 U.S. 825, 831-33, 108 S.Ct. 2182, 100 L.Ed.2d 836 (1988); Cooper Indus., Inc. v. Compagnoni, 162 F.Supp.2d 702, 709-10 (S.D.Tex.2001).

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In this case, Northwest determined, within eighteen months of the date the first payment would have been made un╜der the DRO, that the DRO, as modified, was a QDRO. Thus, Mary satisfied ERISA's requirements for alienating pen╜sion plan proceeds. Requiring Mary to satisfy state law perfection requirements would conflict with ERISA's policy of en╜suring that plan sponsors are subject to a uniform body of law. See Egelhoff v. Egel╜hoff, 532 U.S. 141, 148, 121 S.Ct. 1322, 149 L.Ed.2d 264 (2001) (principal goal of ERISA is to establish uniform scheme with standard procedures; uniformity is impossible if plans are subject to different legal obligations in different states); Minnesota Chapter of Associated Builders & Contractors, Inc. v. Minn. Dep't of Pub. Safety, 267 F.3d 807, 810-11 (8th Cir.2001) (ERISA's goal is to minimize administra╜tive and financial burden of complying with conflicting state directives, and to prevent potential for conflicts in substantive law requiring tailoring of plans to peculiarities of multiple local laws), cert. ═ denied 535 U.S. 1096, 122 S.Ct. 2292, 152 L.Ed.2d 1051 (2002); Compagnoni, 162 F.Supp.2d at 710 (imposing state law perfection re╜quirements would create choice-of-law dif╜ficulties, frustrating objective of ensuring uniformity of ERISA administration).

We further conclude that Mary's inter╜est in the plan proceeds relates back to the date of the initial DRO. See Nelson v. Rametter, 322 F.3d 541, 544 (8th Cir.2003) ("A person awarded a lump-sum distribu╜tion from an ERISA plan pursuant to a divorce decree has a direct interest in plan funds while the plan reviews the DRO to determine whether it constitutes a QDRO."); Gendreau v. Gendreau, 122 F.3d 815, 818 (9th Cir.1997) (wife's interest in pension plans was established at time of divorce decree; husband's interest was concomitantly limited at that time, or sub╜ject to being limited at any time wife ob╜tained QDRO, much like property owner's rights may be subject to divestment by contingent interest); Compagnoni, 162 F.Supp.2d at 711-12 (wife had possessory interest in benefits once first DRO bad been entered although interest was unen╜forceable until QDRO was obtained); cf. 29 U.S.C. ╖ 1056(d)(3)(H) (any determina╜tion made within eighteen months of the order, or modification of the order, will be applied prospectively). Mary had eighteen months pursuant to section 1056(d)(3)(H)(ii) to qualify her DRO, and "[i]f within the 18-month period ... the order (or modification thereof) is deter╜mined to be a qualified domestic relations order the plan administrator shall pay the segregated amounts ... to the person . . . ." (Emphasis added). The plan admin╜istrator, by plan procedures, cannot shor╜ten this eighteen month qualification peri╜od.

Because the DRO preceded the IRS's notice of tax lien, and Northwest deter╜mined within the requisite eighteen months that the DRO qualified as a QDRO, see 29 U.S.C. ╖ 1056(d)(3)(H)(v) (computation of time), Mary was a judg╜ment lien creditor with priority as of July 1995, when the DRO was entered. She is thus entitled to the plan proceeds free of the IRS lien.

One other related issue should be ad╜dressed regarding the finality of the July 1995 Texas DRO. The Texas judge signed an order prepared and approved by the parties which stated:

The Court retains jurisdiction to amend this Order so that it will consti╜tute a qualified domestic relations order under the Plan even though all other matters incident to this action or pro╜ceeding have been fully and finally ad╜judicated. If the Plan determines at any time that changes in the law, the administration of the Plan, or any other circumstances make it impossible to cal╜culate the portion of a distribution awarded to Alternative Payee by this Order and so notifies the parties, either or both parties shall immediately peti╜tion the Court for reformation of this Order.

The intent of the July 1995 DRO, to quali╜fy under the applicable Northwest plans, is clear. The parties and the court recog╜nized the order may need changes to quali╜fy. Northwest did require certain changes to qualify, Mary asked the Texas court twice to reform the DRO before North╜west accepted the DRO as a QDRO. This process is anticipated by the law, which provides for segregation of the funds by the plan administrator for up to eighteen months to qualify the DRO as a QDRO. See 29 U.S.C. ╖ 1056(d)(3)(H). Our hold╜ings in Nelson and here, recognizing the DRO establishes a "direct interest in plan funds," and upon qualification, the interest relates back to the initial DRO date, fur╜ther the statutory scheme to protect em╜ployee retirement benefits for beneficiaries of the plans, including divorced spouses.

As a legal matter, when the DRO issued, Francis was no longer the owner of 90 percent of the Northwest ERISA plans. Mary was awarded this share as part of the divorce. Mary, the property, and the amount were identified clearly, only the details of qualification remained to trans╜form the DRO into a QDRO.

III. CONCLUSION

Since we conclude Mary was a judgment lien creditor, we do not address whether she was also a purchaser under section 6323(a). Accordingly, we reverse the sum╜mary judgment with regard to Mary Tay╜lor, and remand with instructions to enter judgment in conformity with this opinion.

LOKEN, Circuit Judge, dissenting.

The lien priority issue in this case in╜volves the interplay of two federal statuto╜ry regimes, ERISA and the Internal Rev╜enue Code. The Code provides that a judgment lien, when perfected, has priority over an existing federal tax lien unless notice of the tax lien has been filed in accordance with state law. See 26 U.S.C. ╖ 6323(a), (f). ERISA provides that a for╜mer spouse may acquire an enforceable fight to a participant's pension plan bene╜fits pursuant to the provisions of a "quali╜fied domestic relations order" (QDRO). 5 Here, the IRS more or less concedes that the Texas divorce court's domestic rela╜tions order granted Mary Taylor a judg╜ment lien on Francis Taylor's ERISA plan benefits. The issue, then, is whether her lien on those plan benefits is entitled to priority over the IRS's tax liens under ╖ 6323(a).

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5. Significantly, the QDRO provisions of ERISA appear in both the Internal Revenue Code and the Title 29 labor laws. See 29 U.S.C. ╖ 1056(d); 26 U.S.C. ╖ 414(p). I will cite to the Code provisions in this dissent.

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Federal law governs whether a judg╜ment lien created by state law is perfected for purposes of ╖ 6323(a). The federal rule is that a lien is perfected, or choate, "when the identity of the lienor, the prop╜erty subject to the lien, and the amount of the lien are established." United States v. Pioneer Am. Ins. Co., 374 U.S. 84, 89, 83 S.Ct. 1651, 10 L.Ed.2d 770 (1963) (quota╜tion omitted). A Treasury Regulation now codifies this principle. 26 C.F.R. ╖ 301.6323(h)-1(g). Though Mary Tay╜lor's judgment lien was created by state law, ERISA provides that, to be perfect╜ed-that is, enforceable against Francis Taylor's plan benefits-the state court or╜der must be a QDRO. And Congress's definition of a QDRO incorporates the sub╜stance of the federal law definition of a perfected lien: a domestic relations order qualifies as a QDRO if it clearly specifies the plan participant, the alternative payee (the lienholder), each plan to which the order applies, the amount or percentage of the benefits to be paid to the alternate payee, and the number of payments or period to which the order applies. 26 U.S.C. ╖ 414(p)(2).

Given this overlap between the judicially developed federal rule of perfection, and the statutory elements of a QDRO, I agree with the court that a QDRO is a perfected judgment lien for purposes of the priority rules of ╖ 6323(a). Like the court, I reject the IRS's argument that, to be perfected under ╖ 6323(a), the judgment lien created by a QDRO must also satisfy any levy or seizure requirements generally applicable to liens created by the laws of that State. Congress codified the perfection requirements for a QDRO in another section of the Internal Revenue Code, and ERISA would preempt any local law that inter╜fered with its anti-alienation provisions. In the absence of a Treasury Regulation specifically addressing the relationship be╜tween Code ╖╖ 6323(a) and 414(p)(2), I decline to apply a general reference to local law in a pre-existing Treasury Regu╜lation, 26 C.F.R. ╖ 301.6323(h)-1(g), in a manner inconsistent with the QDRO per╜fection provisions of ERISA.

There remains the question whether Mary's judgment lien was perfected (ac╜quired QDRO status) prior to the IRS filing notice of its tax liens in Dallas Coun╜ty, Texas, in late December 1995. Mary's judgment lien arose on July 28,1995, when the Texas divorce court entered a domestic relations order awarding her a 90% inter╜est in Francis Taylor's ERISA plan bene╜fits. Northwest Airlines as plan adminis╜trator determined that amended versions of that order qualified as QDROs, long after the tax liens were filed in December 1995. The court nonetheless concludes that Mary's QDRO-perfected lien has pri╜ority because "Mary's interest in the plan proceeds relates back to the date of the initial [divorce court order]." Ante at 952. I disagree.

ERISA provides that, when a domestic relations order is submitted for a QDRO determination, the plan administrator must make the determination "within a reason╜able period after receipt of such order," 26 U.S.C. ╖ 414(p)(6)(A)(ii), and must segre╜gate plan benefits that would be payable to the alternate payee (here, Mary Taylor) for up to, eighteen months while it makes that determination, ╖414(p)(7). See Ho╜gan v. Raytheon, Co., 302 F.3d 854, 857 (8th Cir.2002). If the administrator deter╜mines within the eighteen-month approval period that the submitted order or a "mod╜ification" of that order is a QDRO, it must pay the segregated amounts to the alter╜nate payee. 26 U.S.C. ╖ 414(p)(7)(B); see Trustees of the Dirs. Guild of Am.-Produc╜er Pension-Benefits Plans v. Tise , 255 F.3d 661 (9th Cir. 2000). In that situation, although the issue is not free from doubt, I do not take issue with the court's conclu╜sion that QDRO status should "relate back" to the entry of the initial domestic relations order for purposes of ╖ 6323(a) lien priority because ERISA has conferred a direct interest in the segregated plan funds at that earlier date. 6 Cf. Nelson v. Rametter, 322 F.3d 541, 544 (8th Cir2003) (for bankruptcy purposes, alternative pay╜ee acquires QDRO interest in plan funds on the date the domestic relations order is first entered); Gendreau v. Gendreau, 122 F.3d 815, 818 (9th Cir.1997) (same), cert. denied, 523 U.S. 1005, 118 S.Ct. 1187, 140 L.Ed.2d 318 (1998).

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6. My doubt stems from the fact that the initial domestic relations order, if seriously defi╜cient, may not satisfy the QDRO requirements in ╖ 414(p)(2) that correspond to the elements that make a judgment lien choate under fed╜eral common law. Here, for example, the July 28, 1995, order did not identify to which of the three Northwest Airlines plans it ap╜plied and thus did not clearly define the 90% interest that Mary was awarded. In such a case, for purposes of priority against a federal tax lien, I am not sure whether QDRO. status should only relate back to the date the defi╜cient domestic relations order was modified, or all the way back to the entry of the initial, non-choate domestic relations order. I need not resolve that question here.

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But assuming the court has adopted a correct relation-back principle, it has mis╜applied that principle to the facts of this cage. Unlike the plan administrator in Cooper Indus., Inc, v. Compagnoni, 162 F.Supp.2d 702 (S.D.Tex.2001), Northwest Airlines did not invite Mary and Francis Taylor to submit a modified domestic rela╜tions order to cure defects in the July 28, 1995, order. Rather, Northwest Airlines as plan administrator issued three letters be╜tween October 16 and November 3, 1995, initially determining that the July 28, 1995, domestic relations order did not qualify as a QDRO with respect to any of the three plans, and advising the Taylors that these initial determinations would become final at the conclusion of the sixty-day appeal period provided for in the three plans. When the Taylors did not appeal, North╜west Airlines issued three final negative determinations. At that point, ERISA ex╜pressly provides that Mary as alternate payee had no further interest in any segre╜gated plan benefits. 26 U.S.C. ╖ 414(p)(7)(C). Consistent with the stat╜ute, Northwest Airlines then paid the seg╜regated benefits for the months from July 1995 to January 1996 to Francis Taylor. At that point, though the eighteen-month period had not expired, Mary's claim to a perfected judgment lien as of July 28, 1995, was finally rejected. 7

7. The court has no support for its assertion that "[t]he plan administrator, by plan proce╜dures, cannot shorten [the] eighteen month qualification period." Ante at 952. The asser╜tion is contrary to the plain language of the statute, which requires a QDRO determina╜tion "within a reasonable period," provides that affected benefits must be segregated while the determination is made, but places an eighteen-month limit on the plan adminis╜trator's duty to segregate. The assertion is also contrary to the Department of Labor's interpretation of the QDRO provisions: "the '18-month period' during which a plan administrator must preserve the 'segregated' amounts . . . is not the measure of the reason╜able period for determining the qualified sta╜tus of an order and in most cases would be an unreasonably long period of time to take to review an order." U.S. Dep't of Labor, Em╜ployee Benefits Sec. Admin., QDROs-The Di╜vision of Pensions Through Qualified Domestic Relations Orders, Question 2-12 at p. 19, available online at < http://wvw.dol.gov/ebsa/Publications/qdros.html>.

As the court notes, the Texas court en╜tered a modified domestic relations order on January 8, 1996, after the plan adminis╜trator's final negative determinations. The Taylors submitted that order to Northwest Airlines as plan administrator. Northwest Airlines again issued three no╜tices that it had received a domestic rela╜tions order (one notice for each plan), which is the first step in the QDRO-determination process. See 26 U.S.C. ╖ 414(p)(6)(A)(i). In June 1996, North╜west Airlines finally determined that the January 8, 1996, order qualified as a QDRO with respect to Francis Taylor's savings plan and stock plan benefits. However, on April 15, 1996, Northwest Airlines initially determined that the Janu╜ary 8 order did not qualify as a QDRO with respect to Francis Taylor's retire╜ment plan benefits. Again, the Taylors failed to appeal within the plan's sixty-day appeal period, and that determination be╜came final. Again; after the appeal period expired, the Taylors submitted another modified domestic relations order, entered by the Texas court on August 29, 1996, which Northwest Airlines finally deter╜mined to be a QDRO on January 7, 1997.

On this undisputed record, I conclude that the plan administrator's QDRO deter╜minations did not grant Mary Taylor a perfected judgment lien interest in Francis Taylor's plan benefits prior to January 8, 1996. As the IRS properly filed notice of its liens in late December 1995, the federal tax liens have priority over Mary's judg╜ment lien under ╖ 6323(a). Accordingly, I respectfully dissent.

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