we have jurisdiction to address the merits of Holder’s challenge to the court’s restitution order. In these circumstances, we think the legal principles are clear that state law determines whether a property interest exists in the first instance, but federal law determines whether and how that property may be attached. “Once it has been determined that state law creates sufficient interests in the taxpayer to satisfy the requirements of the federal tax lien provision, state law is inoperative to prevent the attachment of liens created by federal statutes in favor of the United States.” Drye v. United States, 528 U.S. 49, 52, 120 S.Ct. 474, 145 L.Ed.2d 466 (1999) (citing United States v. Bess, 357 U.S. 51, 56-57, 78 S.Ct. 1054, 2 L.Ed.2d 1135 (1958)); see id. at 61, 78 S.Ct. 1054 (<HOLDING>). There is little doubt under Missouri law that
holding that bankruptcy court is without jurisdiction to control disposition of chapter 13 debtors property that is not property of the bankruptcy estate unless the property is related to the bankruptcy proceedings of the code holding that the right to disclaim property under state law does not defeat a federal tax lien because the taxpayer exercised control over the disposition of the property holding that a property right that comes into existence by court action such as a judgment lien does not relate back to some earlier date to destroy the priority of a federal tax lien holding that a state disclaimer law which applies retroactively and treats the disclaimant as having predeceased the decedent does not defeat a federal tax lien that has already attached to the disclaimants property holding that a taxpayers interest as an heir to his mothers estate constituted property or a right to property to which  federal tax liens attached  despite his exercise of the prerogative state law accorded him to disclaim the interest retroactively