The court considered whether the automatic bankruptcy stay (11 U.S.C. § 362) precludes postpetition creation, perfection, and enforcement of tax liens, under Utah law, for real property taxes that are assessed postpetition. Section 362(b)(3)'s exception to the stay allows postpetition perfection of an interest in property to the extent that such perfection is allowed by 11 U.S.C. § 546(b). However, the court ruled that the exception was inapplicable, concluding that it allows postpetition perfection of a property interest only when a "generally applicable law" provides that perfection will be effective against one who acquired rights in the property prior to the date of perfection. The court found nothing in the Utah tax laws that allows tax liens to take priority over those whose interests attached to real property after taxes were assessed but before the tax lien was perfected. Therefore, the automatic stay precluded postpetition creation, perfection, and enforcement of tax liens created by Utah law.