The following excerpt is from In re Old Carco LLC, 538 B.R. 674 (Bankr. S.D.N.Y. 2015):
Harper v. Virginia Dep't of Taxation, 509 U.S. 86, 98, 113 S.Ct. 2510, 125 L.Ed.2d 74 (1993), and the individual equities of the case or the party's reliance on the old rule are irrelevant:
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