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recoupment there didn't eliminate all opportunity for the
defendant to obtain complete justice with respect to the
transaction in issue, whereas barring recoupment in our case
would amount to denying complete justice. To allow an
affirmative recovery arising from the same transaction to bar or
limit recoupment (as the District Court in United States v.
Timber Access Indus. Co., supra, refused to do) does less
violence to the idea of doing complete justice with respect to
the one transaction than would allowing an unrelated affirmative
recovery (like that in our case with respect to the previously
taxed property credit) to have such a limiting effect. Thus,
there was more reason in United States v. Timber Access Indus.
Co., supra, than there is in our case to limit recoupment by the
amount of the affirmative recovery, and nevertheless the District
Court didn't do so. United States v. Timber Access Indus. Co.,
supra, which is cited and discussed at some length in 6 Wright et
al., Federal Practice & Procedure, sec. 1427, at 197-198 n.8 (2d
ed. 1990), illustrates the point that another affirmative
recovery with its own independent jurisdictional basis, even when
it arises from the same transaction from which a recoupment
defense or counterclaim arises, does not bar or limit recoupment.
It is appropriate to use these non-tax cases, and most
especially Reiter v. Cooper, in the tax area. Reiter v. Cooper
not only cited Bull v. United States at a crucial point in its
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