In the Matter Of: John Davis Orr, Debtor. Internal Revenue Service v. John Davis Orr

DeMOSS, Circuit Judge:

A spendthrift trust beneficiary who extinguished personal federal tax liabilities through bankruptcy now appeals the determination by the district court that distributions from the trust are subject to a prebankruptcy federal tax lien until the tax liability is satisfied. The district court’s order conclusively settles a discrete issue within the bankruptcy case, and is appealable pursuant to 28 U.S.C. § 158(d). We conclude that the federal tax lien on income distributions from this Texas spendthrift trust attached to future distributions at the time of the creation of…