The reasons for our affirmance were stated quite well in the district court’s opinion which appears in 445 F.Supp. 824 (N.D. Cal. 1978). We adopt Judge Renfrew’s opinion to the extent of Parts I, II, and III.A. As to Part III.B, we merely wish to hold that, to the extent an exception to section 3466 might exist for “perfected and specific liens,” the lien of the appellant was not sufficiently perfected and specific to come within any such exception.

Affirmed.