MEMORANDUM OPINION
MERRITT S. DEITZ, Jr., Bankruptcy Judge.
One of the oldest principles of Anglo-American jurisprudence, the doctrine of sovereign immunity, emerges as an early consideration in this dispute between the Internal Revenue Service and a tax-refund merchant seeking safe haven in Chapter 11. The question is before us on an IRS motion to dismiss, for lack of subject matter jurisdiction, the debtor's complaint for a turnover of certain tax refund...
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