Nita B. Leissner - Page 10

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               Petitioner further argues that, following personal discharge           
          in bankruptcy, her underlying tax liabilities did not cease to              
          exist and were not extinguished by the discharge.  Petitioner               
          argues that her personal discharge in bankruptcy was not an in              
          rem discharge, and existing Federal tax liens remained in full              
          force and effect against all assets petitioner owned prior to               
          filing her bankruptcy petition.  Petitioner contends that the               
          effect of her “discharge is to prevent the IRS from collecting              
          the unpaid 1986 and 1987 liabilities from assets acquired by the            
          Petitioner subsequent to the date her bankruptcy petition was               
          filed.”                                                                     
          V.  Analysis Regarding the Amount of Petitioner’s Tax Liabilities           
          Remaining Unpaid as of July 22, 1998                                        
               We agree with petitioner that an assessed lien filing fee is           
          part of a tax liability.  As petitioner notes, costs of the lien            
          may be included in the amount of the lien under section 6321.               
          Respondent assessed the lien filing fee and makes no argument               
          that he would not seek to collect it from petitioner if she had             
          not received a personal discharge in bankruptcy.  This Court has            
          previously treated assessed collection costs, including lien                
          filing fees, as a part of the taxpayer’s tax liability.  See,               
          e.g., Sponberg v. Commissioner, T.C. Memo. 2002-177; Hansen v.              
          Commissioner, T.C. Memo. 1996-158.  Consequently, petitioner’s              
          1987 tax liability was not paid in full as a result of the                  






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