Task: Wrong Candidate Generation
Input (English): the court explained: We note at the outset that § 724(b)(2) expressly limits the amount distributable to § 507(a) claimants to the “amount of such allowed tax claim that is secured by such tax lien.” In light of this qualification, it is clear that administrative and priority claimants are able to prime a tax lienholder under § 724(b)(2) only to the extent of the tax lien; if, as in this case, the sum of administrative and priority claims exceeds the amount of the tax lien, the excess amount is relegated to § 721(b)(6) status and paid in accordance with § 726. To hold otherwise would render meaningless the limiting language in § 724(b)(2). (Emphasis added.); see also King v. Bd. of Supervisors of Fairfax County (In re A.G. Van Metre, Jr., Inc.), 155 B.R. 118, 123 (Bankr.E.D.Va.1993) (<HOLDING>); Hargrave v. Township of Pemberton (In re 
 Holding statements: (A) holding that it was not the taxpayers responsibility to pursue the different tax units to which the illegally levied county tax was proportioned as the taxpayer was entitled to recover the full amount of the tax from the county the collecting entity (B) holding that state property tax liens are not entitled to the states statutory interest rate as a matter of law rather the appropriate rate of interest is determined by the equities of each case (C) holding that priority unsecured claimants are entitled to payment only to the extent of the amount of the tax hens then if such claims happen to equal or exceed the amount of statutory tax liens the statutory tax hens are paid behind the claims of junior consensual henholders (D) holding that a tax refund claim must be dismissed if the principal tax deficiency has not been paid in full (E) holding that two federal tax liens had priority as a matter of law over the competing claims for fees and costs of a stakeholderbank
Output (English): holding that two federal tax liens had priority as a matter of law over the competing claims for fees and costs of a stakeholderbank