interests will be taxed.” United States v. Irvine, 511 U.S. 224, 238, 114 S.Ct. 1473, 128 L.Ed.2d 168 (1994). Under Michigan law, a “constructive trust is strictly not a trust at all, but merely a remedy administered in certain fraudulent breaches of trusts.” Soo Sand & Gravel Co. v. M. Sullivan Dredging Co., 259 Mich. 489, 244 N.W. 138, 140 (1932). Accordingly, a constructive trust does not arise until a judicial decision imposes such a trust under Michigan law. The federal tax lien in the present case arose in 1988. Because the constructive trust was not judicially imposed over the 17.83 acres until a decade later, the government argues that the federal tax lien should be given precedence over the plaintiffs’ interest. Even if Michigan law allows the d 74, 478, 145 L.Ed.2d 466 (1999) (<HOLDING>). Only competing claims that meet the federal
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 federal tax lien properly attached to a slatelawcreated right to property that had pecuniary value 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 holding that  522f1 requires a debtor to have possessed an interest to which a lien attached before it attached to avoid the fixing of the lien on that interest 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