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Friday, January 12, 2018
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Circuit Split Update on Sovereign Immunity and Derivative Suits Against the IRS

Ninth Circuit won’t rehear DBSI, creating a split with the Seventh Circuit on Sections 106(a)(1) and 544(b)(1).

Monday, December 11, 2017
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Plan’s Interest Rate Held to Govern Tax Claims, Not the Rate in the IRS Code

‘Strained’ argument by the IRS about recoupment didn’t overcome terms of a confirmed plan.

Thursday, October 12, 2017
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Ninth Circuit Splits with Seventh on Sovereign Immunity and Derivative Suits by a Trustee

Ninth Circuit criticizes the Seventh for making the sovereign immunity waiver meaningless for Section 544(b)(1) suits.

Complex Tax Issues

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