Rouse v. United States (In Re Pronto Enterprises, Inc.)

MEMORANDUM OPINION

ARTHUR B. FEDERMAN, Bankruptcy Judge.

The matter before the Court is a dispute between three creditors over the proceeds generated by the sale of three properties and now held by the Chapter 7 trustee. The issues to be addressed are (1) whether the amount withheld from the purchase price by a purchaser of a debtor's business pursuant to the Missouri successor tax liability statutes constitutes property of the debtor to which a federal tax lien may attach, and (2) what effect does substantive consolidation have on the nature and extent of liens held by creditors of separate…