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80 AFTR action AFTR 2d amended amount appeal apply argues argument assessment Bank bankruptcy Boldface type refers Cite as 80 claim Code collection Comm Company complaint Corp Corporation costs count debtor decision defendant denied Dept determination dismiss Dist district court documents et al evidence F.Supp fact failed Federal fees filed funds granted holding included income Insurance interest Internal Revenue issue John Judge July June jury liability lien limitations loan loss March Matter ment motion notice Office Ohio paid parties payment person plaintiff reasonable record refers to volume Reporter Robert Rule sentence Sept Service Smith statute suit taxpayer Thomas tion Treasury trial Trust U.S.C. section United