affirm. 1 . Rizzo is incorrect that the linguistic difference between § 507(a)(8)(E) and subsection (a)(8)(C) — which excludes taxes "required to be collected or withheld and for which the debtor is liable in whatever capacity " — matters. Id. (emphasis added). This portion of subsection (a)(8)(C) simply codifies what the Supreme Court had already held in United States v. Sotelo, 436 U.S. 268, 98 S.Ct. 1795, 56 L.Ed.2d 275 (1978): that, even in the absence of such statutory language, a debtor’s derivative liability for corporate taxes is non-dischargeable in bankruptcy. Id. at 274-75, 278-81, 98 S.Ct. 1795. 2 . This principle is not at all alien to the federal system, as federal tax obligations have been interpreted in an identical manner. See Gallet-ti, 541 U.S. at 123, 124 S.Ct. 1548 (<HOLDING>); United States v. Holmes, 727 F.3d 1230, 1235
holding that the assessment is given the force of a judgment and if the amount assessed is not paid when due administrative officials may seize the debtors property to satisfy the debt holding a corporate officer individually liable without piercing the corporate veil because he specifically directed sanctioned and actively participate in the maintenance of the nuisance holding that a derivatively liable corporate officer need not be separately assessed because the consequences of the assessment  attach to the tax debt without reference to the special circumstances of the secondarily liable parties holding that a corporate officer signing a contract in his corporate capacity is generally not liable for damages under the contract holding that cause of action for malpractice did not arise until the tax deficiency was assessed because prior to assessment the plaintiff had not been injured