WILKINS, Circuit Judge:
Linda Gale Motley appeals an order of the district court holding that assessments imposed by the Commissioner of the Virginia Department of Motor Vehicles ("the Department") are excise taxes for purposes of 11 U.S.C.A. § 507(a)(7)(E) (West Supp.1990) and, therefore, are not debts dischargeable in bankruptcy pursuant to 11 U.S.C.A. § 523(a)(1)(A) (West Supp.1990). We affirm in part and reverse in part.
I.
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