Estate of Frank A. Branson - Page 65

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          of any other Federal court of law, e.g., the Federal District               
          Courts, including the power to apply equitable principles such as           
          equitable recoupment.  Because the Court holds as much today, I             
          concur in our decision.                                                     
               PARR, FOLEY, VASQUEZ, THORNTON, and MARVEL, JJ., agree with            
          this concurring opinion.                                                    

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