DYK, Circuit Judge.
This is the second time this case has come before this court. This case involves a claim for interest netting under § 6621(d) of the Internal Revenue Code. 26 U.S.C. § 6621(d) (2000). The Federal National Mortgage Association ("FNMA") asserts that it is entitled to a refund of interest paid by the taxpayer to the Internal Revenue Service ("IRS") based on the theory that mutual indebtedness of the taxpayer and the IRS for different tax...
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