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Fourth and Third Circuits Give Priority to Obamacare’s Individual Mandate Penalty

The Fourth Circuit sides with the Third on the Affordable Care Act’s ‘individual mandate.’ Majority says it was a tax measured by income, thus giving the IRS a priority tax claim.
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Second Circuit Says Orderly Liquidation Value Is Proper for a Retailer in Chapter 11

The Second Circuit adapts Rash to value the lender’s collateral in chapter 11 where there was a going-concern sale.
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