The Internal Revenue Service (IRS) (creditor) assessed the McDermotts (debtors) for unpaid federal taxes. The IRS created a federal tax lien on all of the McDermotts’ current and after-acquired property. The McDermotts were also in debt to Zions First National Bank (creditor). The bank obtained a judgment against the McDermotts on all of their current and after-acquired property. The bank filed notice of the judgment lien on July 6. The IRS filed notice of the federal tax lien on September 9. On September 23, the McDermotts acquired a parcel of real property. The IRS, the bank, and the McDermotts entered into an escrow agreement. Under the agreement, the IRS and the bank released any claim on the real property but reserved their rights to the cash proceeds of the sale based on their priority as of the date the McDermotts acquired the property. The McDermotts brought an interpleader to determine the priorities. The district court granted priority in the property to the bank's lien and the court of appeals affirmed.