MCTLA liens, which include Portnoff ' s commissions, legal fees and costs, do not qualify as taxes under RETSL and , therefore , are not payable as second priority taxes under RETSL Section 5860.20S (d ) (2 ) . Instead, those MCTLA liens are only payable to the extent that there are any excess funds available for payment of fourth priority liens under RETSL Section 5860 . 205 (d) (4) .