Case Summary:
Creditor (Snap-On Tools) did not lose its purchase money status in its security interest in tools sold to debtor so as to make its lien in the tools avoidable by the debtor. Case did not involve a cross-collateralization, after-acquired property clause or a consolidation of security interests. The only consolidation which occurred involved the outstanding balances from various purchases made by the debtor. Where security interest does not specify how payments are to be applied, court can apply the payments pursuant to Wisconsin's "first-in, first-out" payment provision -- Wis. Stat. Ann. § 422.418(3) (West 1988).
Statue/Rule References:
Wis. Stat. § 409.107 -- Purchase money security interest
Wis. Stat. § 422.418 -- Allocation of payments - "first in-first out"
Key Terms:
Security Interests - Allocation of Payments
Security Interests - Consolidation
Security Interests - Purchase Money