Court of Appeals for the Sixth Circuit February 3, 1995, 93-4315 (In Re Elmer Walter Dorla Walter, Debtors. United States of America v. John J. Hunter, Trustee)

MILBURN, Circuit Judge.

The defendant-trustee, John J. Hunter, appeals the district court’s order reversing a decision of the bankruptcy court and holding that the trustee could not avoid the statutory liens of the plaintiff-internal Revenue Service (the “IRS”). The sole issue on appeal is whether the district court properly determined that the trustee could not, under the Bankruptcy Code, 11 U.S.