No. 88-2567.

896 F.2d 377 (1990)

UNITED STATES of America (Internal Revenue Service), Creditor-Appellant, v. Louis George BARBIER, Ruth Dean Barbier, Debtors-Appellees.

United States Court of Appeals, Ninth Circuit.

Decided February 13, 1990.

Attorney(s) appearing for the Case

John J. Boyle, Dept. of Justice, Tax Div., Washington, D.C., for creditor-appellant.

Geoffrey L. Giles, Reno, Nev., for debtors-appellees.

Before POOLE, REINHARDT and O'SCANNLAIN, Circuit Judges.

O'SCANNLAIN, Circuit Judge:

In this Chapter 13 bankruptcy proceeding, the Internal Revenue Service, as a lien creditor, appeals the district court's affirmance of the bankruptcy court's determination that the IRS lien was unsecured. 84 B.R. 190.


In 1985, the Internal Revenue Service ("IRS") assessed federal income tax deficiencies against Louis George Barbier and Ruth Dean Barbier ("the Barbiers") for tax years 1980...

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