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.
I
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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