Romani Industries, Inc. (RI) perfected a lien against Francis J. Romani’s Pennsylvania property by filing its judgment in the county clerk’s office. Later, the Internal Revenue Service filed notice of liens on Romani’s property for unpaid taxes. Romani died, leaving a single property. Romani’s estate (defendant) asked the court for permission to transfer the property to RI. The federal government objected, arguing it had a right to “be paid first” under the federal priority statute, 31 U.S.C. § 3713(a), despite the fact that the Federal Tax Lien Act of 1966, 26 U.S.C. § 6321 et seq. (FTLA), gave it no such priority. The court authorized the transfer, which the Superior Court of Pennsylvania and the Supreme Court of Pennsylvania affirmed. The government petitioned the United States Supreme Court for certiorari, which was granted.