District Court, D. Alaska August 3, 2001, A00-0206 CV (JKS) (Barstow v. Internal Revenue Service)

ORDER

SINGLETON, Chief Judge.

INTRODUCTION

Presently before the Court is an appeal filed by Appellant William Barstow, III, Chapter 7 Trustee, for the bankruptcy estate of MarkAir, Inc. (“MarkAir” or “Debt- or”) of the United States Bankruptcy Court for the District of Alaska’s decision that tax lien subordination under 11 U.S.C.