80 STAT. ]
PUBLIC LAW 89-719-NOV. 2, 1966
••(I) is in pr<)perty (A) subject, at the time of tax lien filing, to file lien imposed by section 6321, and (B) covered by the terms of a written agreement entered into before tax lien filing, and "(2) is protected undei- local law against a judgment lien arising, as of the time of tax lien filing, out of an unsecured obligation. ^'(e) PRIORITY OF INTEREST AND EXPENSES.—If the lien imposed by section 6321 is not valid as against a lien or security interest, the priority of such lien or security interest shall extend to— "(1) any interest or carrying charges upon the obligation secured, "(2) the reasomible charges and expenses of an indenture trustee or agent holding the security interest for the benefit of t he holder of the security interest, "(3) the reasonable expenses, including reasonable compensati(m for attorneys, actually incurred in collecting or enforcing the obligation secured, (4) the I'easonable costs of insuring, preserving, or repairing (he property to which the lien or security interest relates, "(5) the reasonable costs of insuring payment of the obligation secured, and (6) airu)unts paid to satisfy any lien on the property to which the lien or security interest relates, but only if the hen so satisfied is entitled to priority over the lien imposed by section 6321, to the extent that, under local law, any such item has the same priority as the lien or security interest to which it relates. " (f) PLACE FOR FILING NOTK-E; FORM.—
"(1) PLAGE FOR FILINO.—The notice refen-ed to in subsection (a) shall be filed— '* {A) UNDER STATE LAWS.—
- '(i) REAL PROPERTY.—In
the case of real property, in one office within the State (or the county, or other governmental subdivision), as designated by the laws of such State, in which the property subject to the lien is situated; and "(ii) PERSONAL PROPERTY.—In the case of personal property, whether tangible or intangible, in one office within the State (or the county, or other governmental subdivision), as designated by the laws of such State, in which the property subject to the lien is situated; or " (B) WiiTi CLERK OF DISTRICT COURT.—In the office of the clerk of the United States district court for the judicial district in which the property subject to the lien is situated, whenever the State has not by law designated one office which meets the requirements of subparagraph (A); or "(C)
W I T H RECORDER or DEEDS OF THE DISTRICT OF COLUM-
BIA.—In the office of the Recorder of Deeds of the District of Columbia, if the property subject to the lien is situated in the District of Columbia. "(2)
SITUS OF PROPERTY SUBJECT TO LIEN.—For purposes of
paragraph (1), property shall be deemed to be situated— " (A) REAL PROPERTY.—In the case of real property, at its physical location; or " (B) PERSONAL PROPERTY.—In the case of personal property, whether tangible or intangible, at the residence of the taxpayer at the time the notice of lien is filed. F^or purposes of paragraph (2)(B), the residence of a corporation or partnership shall be deemed to be the place at which the
1129 68A Stat. 779. 26 USC 6 3 2 1.
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