fund taxes fall within the ambit of Code § 507(a)(8)(C) and are therefore entitled to priority treatment. Despite the Debtor’s argument to the contrary, it is also well established that civil penalties assessed in relation to unpaid trust fund taxes, such as those assessed against the Debtor under I.R.C. § 6672, are nondischargeable in bankruptcy, and are to be accorded the same priority as the underlying taxes themselves. See Matter of Taylor, 132 F.3d 256, 261 (5th Cir.1998); In re Mosbrucker, 220 B.R. 656, 658 (Bankr.D.N.D.1998); In re Felland, 153 B.R. 835, 839 (Bankr.W.D.Wis.1993); In re LMS Holding Co., 149 B.R. 684 (Bankr.N.D.Okla.1993); In re Hughes, 137 B.R. 614, 615 (Bankr.E.D.Va.1992); see also, United States v. Sotelo, 436 U.S. 268, 98 S.Ct. 1795, 56 L.Ed.2d 275 (1978) (<HOLDING>) (Sotelo, a Bankruptcy Act case, was
holding that plaintiff could not recover medical bills that were discharged in bankruptcy recognizing that the party who primarily benefited from income for taxes that are due and owing should be declared exclusively responsible for the tax liability penalty and interest holding that discharged debtor is protected only from in personam liability not in rem liability on lien given as security for mortgage loan holding that operates as a charge of debtors in personam tax liability not debtors in rem tax liability holding that responsible person liability under irc  6672 although labeled a penalty was actually a tax liability that could not be discharged in bankruptcy