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created by contract or agreement. See Fla. Stat. ch. 679.102
(1996) (repealed effective Jan. 1, 2002, Fla. Stat. Ann. ch.
679.102 (West 2003)); In re Bertelt, 206 Bankr. 579, 585 (Bankr.
M.D. Fla. 1996). This statute does not affect the filing of
Federal tax liens within the State of Florida, which are instead
governed by the Registration Act. See In re Bertelt, supra at
584-585. Under the Registration Act, the proper place for filing
is the circuit court in the county where the taxpayer resides.
Thus, there is one office within Florida where the Federal tax
lien should be filed, and the liens in issue were filed in that
place.
Value of Pension Plan Subject to Lien
Petitioner argues that, if the Court sustains the liens,
which we have, we should further determine the value of
petitioner’s interest in the pension plan that is subject to the
lien. Petitioner argues that the value of the pension plan is
limited to the value at the time the lien was filed and, further,
that the lien, and any levy that might occur to enforce it, is
subordinate to a claim by petitioner’s former wife for 50 percent
of the value.
Respondent contends that the Court does not have
jurisdiction under section 6330 to determine the value of
petitioner’s asset at the time the bankruptcy proceeding was
commenced. Even if the Court concludes that it does have
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