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Thirdly, Judge Beghe's concurrence relies on the analysis of
equitable recoupment in Justice Stevens' dissent in United States
v. Dalm, 494 U.S. 596, 612-623 (1990). Although much
understanding may be gleaned from a distinguished jurist's
dissent, the fact remains that the dissent is what the Supreme
Court's majority rejected.
COHEN and WHALEN, JJ. agree with this dissent.
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