law, to establish such priority. Therefore, a security interest comes into existence only at the time prescribed in the preceding sentence notwithstanding any rule or principle of local law which permits the relation back of any requisite action to a date earlier than the date on which it is actually performed. H.R.Rep. No. 89-1884, at 49 (1966) (emphasis added). Our conclusion that the Treasury Regulation is a reasonable construction of 26 U.S.C. § 6323(h)(1)(A) is bolstered by the fact that federal courts have, with one exception, uniformly applied it to bar state laws that would otherwise permit later actions to relate back in time, without any suggestion that it might be an impermissible construction of the statute. See Haas v. IRS (In re Haas), 31 F.3d 1081, 1091 (11th Cir.1994) (<HOLDING>); Flagstar Bank, FSB v. Eerkes, No. C12
holding that foreclosure of prior mortgage extinguished second mortgage holding that the note and the mortgage must coexist to give the mortgage validity holding that state equitable principles would retroactively reinstate an erroneously released mortgage but that those principles were nonetheless barred by treas reg  301 6323hla2s prohibition against relation back holding that a mortgage transfer does not take effect until the mortgagee gives value in exchange for the mortgage holding that although alabama state law would give a mortgagee who erroneously recorded a release of a mortgage an equitable right to have the mortgage retroactively reinstated reinstatement would have resulted in relating back the perfection of the mortgage to the original recording date in violation of treas reg  3016323hla2