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" ... Claimant shall pay nothing to Respondent on the Counterclaim. The Panel treated the Counterclaim solely as setoff against the assigned promissory note. ... "
" ... The next wrinkle was the interaction between the bankruptcy exemption statute and the bankruptcy setoff provision. In bankruptcy, debtors are able to exempt certain property by statute, i.e., property that is protected from creditors. However, as noted by the court, another section of the bankruptcy code preserves a creditor’s right of setoff. Again, the court explained that courts have reached different conclusions on the result when a tax overpayment is at issue. ... "