United States v. State Street Bank & Trust Co.
United States Bankruptcy Court, D. Delaware
1Opinion of the Court
OPINION1
KEVIN J. CAREY, UNITED STATES BANKRUPTCY JUDGE
Before the Court is an adversary complaint in which the United States of1 America, on behalf of the Internal Revenue Service (the “Government” or “IRS”), asks this Court to recharacterize or equitably subordinate certain secured notes issued in 1996 as part of a chapter 11 reorganization plan. The secured notes were issued to two classes of creditors and known as Series A Junior PIK Notes and Series B Junior PIK Notes. For the reasons that follow, the request to recharacterize the Series A Junior PIK Notes is denied, but the request to…
2Cases cited57 opinions
- Pepper v. LittonSupreme Court of the United States · 1939
- Arizona v. CaliforniaSupreme Court of the United States · 1983
- In the Matter of Mobile Steel Company, Debtor. Elaine E. Benjamin v. Lester Y. Diamond, as Trustee in Bankruptcy for Mobile Steel, Inc.Court of Appeals for the Fifth Circuit · 1977
- United States v. NolandSupreme Court of the United States · 1996
- Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
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