Courts are divided when an exemption claim collides with the government’s right of setoff.
A bankruptcy court’s in rem jurisdiction overrides a claim of sovereign immunity.
‘Exhaustion’ is not required before compelling the IRS to return funds taken in violation of discharge.
Sovereign immunity protects a tribe even after successful veil piercing.
Ninth Circuit won’t rehear DBSI, creating a split with the Seventh Circuit on Sections 106(a)(1) and 544(b)(1).