Reasons for Decision in (Re: [1] Trial on Complaint between FCC, LLC, d/b/a First Growth Capital & the United States on behalf of IRS); For the foregoing reasons, the United States' Tax lien outranks FCC's security interest in the amount of $257,254.20 of proceeds from the accounts owed by Omega & Dynamic; The United States shall submit a judgment consistent with the court's ruling herein w/in 30 days of the entry of these Reasons for Decision. (cath)