The Internal Revenue Service (IRS) (creditor) perfected a notice of federal tax lien against MAKO, Inc. MAKO filed for bankruptcy. RMC (debtor), an unrelated entity, acquired all of MAKO’s bankruptcy estate assets and assumed MAKO’s secured liabilities, including the tax lien. The IRS consented to the plan but failed to file new federal tax lien notices in RMC’s name. RMC, with its affiliates LMS Holding Company and Petroleum Marketing Company, later filed for bankruptcy. RMC alleged that it was entitled to avoid the federal tax liens on the assets it acquired from MAKO. The bankruptcy court held that when RMC assumed the tax lien, the IRS was required to refile the lien notice naming RMC in order to preserve its priority. The district court upheld the bankruptcy court’s decision and the IRS appealed.