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94 AFTR action AFTR 2d agree agreement alleged allowed amended amount appeal apply Appx argues argument assessment Bankruptcy benefit Bktcy Ct Circuit Cite as 94 claim Code collection Comm complaint concluded considered debtor decision defendant denied determination dismiss Dist District Court documents Eastern employee entitled ERISA evidence fact failed farm federal filed finds funds further granted held income income tax interest Internal Revenue Internal Revenue Code issue January Judge judgment July June jurisdiction liability lien limited March matter ment Michigan motion Northern notice objection paid party payments penalties person Plaintiff provides pursuant reasons received record Reference refund Reporter request rule seeks Service Southern statute summary judgment Supp Tax Court tax returns taxpayer Texas tion trust United UNITED STATES DISTRICT wages