Case Summary:
Trustee sought to avoid security interest of bank in a debtor’s per capita interest in tribal gaming revenues. The court concluded that the debtor’s right to the distributions was property of the estate, and the bank failed to properly perfect its security interest when it mailed a copy of the assignment documents to the Ho-Chunk Nation but did not file a financing statement as required by Wisconsin law. Trustee, as hypothetical lien creditor, may avoid security interest for benefit of the estate.

Statute/Rule References:
11 U.S.C. § 541 -- Property of the Estate
11 U.S.C. § 544 -- Trustee as Lien Creditor
Wis. Stat. § 409.310 -- Security Interests - Filing of Financing Statement
Wis. Stat. § 409.317 -- Security Interests - Rights of Lien Creditor

Key Terms:
Perfection of Security Interest
Property of the Estate