In United States v. Carroll, No. 2:09-cv-13505 (E.D.Mich. Jan. 20, 2010), a U.S. district court ruled that the chapter 13 trustees of the Eastern District of Michigan may no longer seek to intercept the federal income tax refunds of chapter 13 debtors. The IRS had soveriegn immunity from bankruptcy court orders requiring the IRS to intercept [...]