Conclusion
The Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 introduced several small but important changes to the bankruptcy code that proved to improve the overall status of secured tax claims. To date however, secured tax claims are not necessarily equal to a priority tax claim. With two additional changes, secured tax claims could receive treatment at least equal to that of a priority claim in all situations. The first change requires that claims which can be classified as either priority or secured, should be classified as priority, reserving the use of collateral other claims. The second change requires the unsecured portion of an undersecured tax claim receive the same treatment as a priority tax claim. With these two changes, secured tax claims, regardless of its ability to qualify as a priority tax claim, will receive at least the same treatment as an unsecured tax claim, removing any disparity between the two classes.