Louis Fusaro - Page 17

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          Hallandale, Florida, the address at which petitioner resided at             
          the time the liens were filed, is in Broward County.                        
               Petitioner argues that Florida statutes provide two places             
          for notices of Federal tax liens to be filed, to wit, with the              
          secretary of state, “by analogy to a Uniform Commercial Code                
          filing”, and in the Circuit Court for the county in which the               
          taxpayer resides, pursuant to the Uniform Federal Lien                      
          Registration Act (Registration Act).  Because, petitioner                   
          contends, there are two places in which the notices of Federal              
          tax lien could have been filed, “the only proper place was in the           
          clerk’s office of the United States District Court.”                        
               Under Florida’s version of the Uniform Commercial Code                 
          (UCC), the office designated for filing is the Office of the                
          Secretary of State.  See Fla. Stat. ch. 679.401 (1996) (repealed            
          effective Jan. 1, 2002, Fla. Stat. Ann. ch. 679.401 (West 2003)).           
          Under the Registration Act, the proper place for filing is in the           
          office of the clerk of the circuit court of the county where the            
          person resides.  See Fla. Stat. ch. 713.901 (1996); see also In             
          re Wesche, 193 Bankr. 76, 77 (Bankr. M.D. Fla. 1996).  Petitioner           
          argues that the two statutes together provide for two separate              
          places for the filing of a Federal tax lien.  However,                      
          petitioner’s argument fails because the Florida UCC does not                
          apply to Federal tax liens.  The policy and the subject matter of           
          Florida’s version of the UCC cover consensual security interests            






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