twenty two a why that is not apply to this case or should apply in the way that apartment justice is just it's a little strange because i feel like i'm making the department of justice argument in both unclear and in brady of the department of justice argued strenuously that sixty five eleven and seventy four twenty two work together as one team that's part of a tax refund refer to sixteen times and ha court now with the supreme court basically held an oak or it's said that it applies to taxes penalties and other stocks and other sounds has been defined to include interest on the mouse too and it's also been  summit interpreted whether or not those things that issue in elkhorn fell within the definition of some but it wasn't i didn't understand it could be giving an exclusive definition that only these things fall within the word thought my misunderstanding al dispute between a person in the federal government over the out of their student loan that happened to be collected by the internal revenue service would you would do identify those as the pundits rather so i would you classify or let's leave that out for them if in fact that payment is due to the united states government is that considered of a package of deposit rather wise how would you define under a federal contract and it happens to be collected by the internal revenue service i don't see how that dispute between you know a federal contractor and apartment energy or department  are a lot of payments made under title twenty six here i use are pretty broad it's very broad i mean and again you know the student loan amounts federal contract payments child support all of that is collected under title twenty tax on the income of people who issue you know state local governments who issue bonds i mean they are issuing bonds at three percent their investment product procedure four percent the taxes on that one percent that's their income  afterwards just so that we would start the period in case we were dismissed we thought there were at least we'd start this on the news there is a period we don't even know if there is a period of time because sixty five thirty two that says you're going to track where and it has only to taxpayers and you're not attack there this is what i got my whole nonprofit you want your money back it's a tax idea but i guess you would say sixty five thirty two doesn't apply to you just as long as you file the well i think there is a question of interest because the internal revenue service has said at least those regulations said that there is no interest due on these deposits or whatever every day but if it's a tax then maybe there is interest i mean the reason i ask the question of whether you'd pile the administrative claims i'm just wondering if we have firm which we need decision in what way is your client have flip flopped and seventy four twenty two a at least a half a dozen times i didn't realize until after a fallacy that we're going back and looking at all their arguments in the cases they made years and years ago they flip flop back and forth on this issue time and time again  still haven't told us whether sixty five thirty two a applies they may come in francis and say ok what is six months since you filed your return to sixty five thirty two it doesn't apply there's some other standard that applies and you still falling to see whether they say that we didn't follow but it also includes the same triple language that's in seventy four twenty two and where refers to any tax penalty or other some yes but to atack to buy where's the fact language notice the mailing the secretary to ata eleven and as the supreme court articulated it and williams where the government actually went to the supreme court arguing that the word taxpayer in sixty five eleven it was a limited constraint on who could bring suit and the supreme court said that there were tax analysis that it can't bear the weight of functioning as a limitation and that it just functions just like sixty five eleven as a type of statute of limitations so you're the ira hershon would be that the government position that fifty five thirty two a would have administrative agencies a chance to look at this very technical issue before three to four see if there's obviously if they were to file a case in court the next day the agency would not have had the opportunity to actually feel  appreciate the policy perspective of why you might want to do it but the language to the taxpayer clearly modified all three from that i find that argument so compelling that's why the government made it to the supreme court in the williams case but analysis of the three part language and seventy four twenty two the any some language the question is if tax payer that had sixty five thirty two and two taxes what does that other some language and in sixty five thirty to  it's a deposit in which case doesn't matter whether the acceleration was justified or not if it's a immediately refundable deposit under new york lifetime resident they just get it back even if television is totally justified and  determination as to whether or not the premature deposit well i the new york life says that seventy four twenty two it doesn't apply in cases of deposits so that even if seventy four twenty two generally would apply to not tax amounts that it would be necessary to look at the question of whether it would we have to have  levy actions and so if all of those you know cases still have authority which you know i believe they do then then the position that if anything you know anything