In the Matter of Sylvin S. Perry, Bankrupt. Franchise Tax Board of the State of California v. Curtis B. Danning, Trustee-Appellee

DUNIWAY, Circuit Judge:

OPINION

This case presents a question of first impression — whether the California Franchise Tax Board’s claim for unpaid California personal income taxes, recorded as provided in the California Code, is a perfected lien upon personal property of a bankrupt taxpayer, and entitled to priority under 11 U.S.C. § 107(c)(3), or is insufficiently perfected and thus not good against the trustee or creditors under 11 U.S.C. § 107(c)(1)(B). The referee and the district court held that the lien was not sufficiently perfected. We affirm.

The stipulated facts are as follows: The…