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IN RE GRANT FOREST PRODUCTS, INC.

No. 10-11132 (PJW).

440 B.R. 616 (2010)

In re GRANT FOREST PRODUCTS, INC., et al., Debtors.

United States Bankruptcy Court, D. Delaware.

November 23, 2010.

Attorney(s) appearing for the Case

John A. DiCicco, Acting Assistant Attorney General, Ari D. Kunofsky, Yonatan Gelblum, Trial Attorneys, Tax Division, U.S. Department of Justice, Washington, D.C., for the United States.

Rafael X. Zahralddin-Aravena, Shelley A. Kinsella, Elliott Greenleaf, Wilmington, DE, Jeffrey W. Kelley, Garrett A. Nail, Troutman Sanders LLP, Atlanta, GA, for Ernst & Young, Inc., Monitor and Foreign Representative of the Debtors.

MEMORANDUM OPINION

WALSH, Bankruptcy Judge.

This opinion is with respect to the United States' motion to reconsider and vacate the order dated May 11, 2010 that recognized and enforced a Canadian court order permitting Ernst & Young to file tax returns for two United States subsidiaries of the Canadian parent corporation, Grant Forest Products, Inc. without incurring liability therefor. (Doc. # 71) The issues presented here are whether the order violated...

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