of the fact almost none of these courts actually addressed whether § 506(c) requires an actual expenditure or, alternatively, whether the incurrence of a cost or the extension of credit suffices for recovery under § 506(c). See, e.g., In re Visual Indus., Inc., 57 F.3d 321, 324-26 (3d Cir.1995); In re Senior-G & A Operating Co., Inc., 957 F.2d 1290, 1298-1300 (5th Cir.1992). Instead, these courts merely refer to an “expense” or “expenditure” in the context of a general discussion about the requirements of § 506(c). In addition, ... the Eighth Circuit[ ] has rejected the argument that because a debt was merely incurred, rather than an expenditure paid, § 506(c) does not permit the secured creditor to be surcharged. See IRS v. Boatmen’s First Nat’l Bank, 5 F.3d 1157, 1160 (8th Cir.1993) (<HOLDING>). Finally, the most significant problem with
holding that derivative standing is available to a creditor to pursue avoidance actions when it shows that a chapter 7 trustee or debtorinpossession in the case of chapter 11 is unable or unwilling to do so notwithstanding hartford underwriters holding that property seized by a creditor prior to debtors bankruptcy was property of the estate even though creditor  the irs  held a secured interest  a tax lien  in the property holding that creditor did not have actual knowledge of the bankruptcy filing where the debtor informed creditor of the possibility that a bankruptcy case would be filed holding that unpaid payroll taxes could be surcharged to secured creditor even though no funds were advanced to the debtorinpossession or to the bankruptcy trustee holding that where a security agreement contained collateral other than collateral for which creditor advanced funds to debtor since it secured antecedent debts as well as new debt and the agreement provided that the security interest secured payment and performance of the debtors present and future debts to the creditor the creditor did not have a pmsi and the debtors could avoid the creditors lien on collateral claimed as exempt