Submitted on 01-22-15 9:46 am Message: Client's business is in Receivership. Building is in pre-foreclosure. IRS has filed liens against the legal entity, a Subchapter S corporation and its two shareholders. The client has another business which was placed in to receivership as well due to the cross collateralization clause in the mortgage granted to the bank. The foreclosure hearing on the commercial building is currently set for after the date the IRS is expected to seize assets. Does the IRS and Illinois Department of Revenue tax liens for the unremitted payroll and state sales taxes come before the mortgage?