Does a third party possessing property or rights to property belonging to a taxpayer who has a federal tax lien hold such property subject to the lien?

"[A] third party possessing property or rights to property belonging to a taxpayer holds such property subject to the lien, unless the third party has a prior lien or comes within one of the exceptions listed in 26 U.S.C. 6323." United States v. Bank of Celina, 721 F.2d 163, 166 (6th Cir. 1983). For example, when a federal tax lien had been filed and the builder's escrow agent had knowledge of the tax lien, the escrow agent improperly converted the tax debtor's funds by advancing the proceeds of a construction loan for payment of nonlienable obligations. Allen, 207 F.Supp. at 549-50.