As noted at the outset, resolution of these motions turns on which party has a priority claim to the interpleader fund. Federal law determines the priority of competing liens, governed by the traditional rule of "first in time is first in right."See United States v. City of New Britain, 347 U.S. 81, 85-86 (1954); United States v. Hage, 417 F. Supp. 74, 76 (N.D.N.Y. 1976). As against a federal tax lien, a state lien can take priority only if, in addition to being first in time, it is choate, or fully established, before the federal lien attaches.