When notices of federal tax liens are filed during the decedent’s lifetime, the federal lien has priority over expenses of administration of the decedent’s estate.  In re Estate of Simmons (United States v. Spiekhout), No. 1:15-cv-01097-TWP-MPB (U.S.D.C. S.D. Ind. 7/31/2017); Estate of Friedman v. Cadle Co., No. 3:08CV488 RNC, 2009 WL 7271206, at *3 (D. Conn. Sept. 8, 2009).  However, IRM 5.5.2.4(3) provides that the government “may in its discretion not assert priority over reasonable administrative expenses of the estate.”