Both the Internal Revenue Code and Bankruptcy Code (titles 26 and 11, respectively, of the U.S. Code) contain provisions regarding setoff, a common law right that permits a creditor to offset a mutual debt owing by the creditor to a debtor. Across the various circuits, there have been many opinions issued in attempts to resolve the conflict of these setoff provisions and the Bankruptcy Code provisions involving exemptions from the bankrupt estate, particularly with regard to tax overpayments. .