among his creditors.” Trustees of Amalgamated Ins. Fund v. McFarlin’s, Inc., 789 F.2d 98 (2d Cir.1986). The obligation for unemployment insurance contributions arose from wages that employees earned from NEI, not from the Debtors. Only taxes on wages, salaries, or commissions “earned from the debtor” qualify for seventh priority, and therefore the Debtors’ obligation does not so qualify. 11 U.S.C. § 507(a)(7)(D). Nonetheless, the State contends that the unemployment insurance contributions should be treated as if they were on wages earned from the Debtors, since the Debtors have been assessed personal liability for the unpaid contributions. C.f. United States v. Sotelo, 436 U.S. 268, 98 S.Ct. 1795, 56 L.Ed.2d 275, reh’g denied, 438 U.S. 907, 98 S.Ct. 3126, 57 L.Ed.2d 1150 (1978) (<HOLDING>). The State’s reliance on Sotelo, however, is
holding that permit fees imposed by statute were not taxes holding that failure to pay sales taxes is a breach of trust holding principals personal liability for unremitted withholding taxes nondischargeable even though corporation rather than principal withheld taxes holding unemployment taxes accrued when employees were terminated not when the amount of compensation taxes are determinable holding petitioner could not deduct real estate taxes imposed on property he did not own because these taxes were not imposed on him