In In re Sandia Tobacco Mfrs, Inc., 2018 WL 4964295 (Bankr. D.N.M. Oct. 12, 2018), the Bankruptcy Court for the District of New Mexico recently held that certain outstanding “assessments” arising under the Fair and Equitable Tobacco Reform Act of 2004, 7 U.S.C. §§ 518-519(a), and its accompanying regulations were excise taxes entitled to priority under Section 507(a)(8)(E) of the Bankruptcy Code.

A recent decision by the United States Bankruptcy Court for the Southern District of New York¹ found that a UCC-3 termination statement filed on behalf of a secured creditor was not effective because it lacked the proper authorization.