"Bob Jones Univ. v. Simon" has also been cited and distinguished in the decisions of other cases. In "Security and Exchange Commission v. Credit Bancorp Ltd." as considered by the District Court for the Southern District of New York, the use of liens by the IRS were considered to be too different from the facts of "Bob Jones Univ. v. Simon" for application of the earlier ruling without careful consideration. When the case came before the Second Circuit Court of Appeals, the exceptions put forth by "Bob Jones Univ. v. Simon" were used in part to determine the case.