BARKSDALE, Circuit Judge:
Overseas Inns S.A. P.A. (Overseas), seeks to recover income taxes assessed and collected by the IRS, primarily contending that comity should be extended to a Luxembourg court approved plan of reorganization which treated the IRS as a general, rather than a priority, creditor. The district court declined to do so and granted the United States summary judgment. Finding no error, we AFFIRM.
I.
The parties stipulated in district...
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