1413 (1984), reprinted in 1984 U.S.C.C.A.N. 697, 1445, 2101; see also Donahue v. United States, 33 Fed. Cl. 600, 606 n. 2 (1995) (quoting this portion of the legislative history and accepting the premise that agencies other than the IRS were not previously allowed setoff against tax refunds). But this statement is flatly contradicted by numerous early cases in which the government did set off tax refunds against nontax liabilities. See, e.g., Cherry Cotton Mills v. United States, 327 U.S. 536, 537, 66 S.Ct. 729, 90 L.Ed. 835 (1946) (involving a debt owed to the Reconstruction Finance Corporation, a federal agency, that was set off as an allowable counterclaim against one of its debtors in a suit by that debtor for a tax refund); Luther v. United States, 225 F.2d 495 (10th Cir.1954) (<HOLDING>); Malman v. United States, 202 F.2d 483, 485
holding that a shareholders status as a guarantor of a corporations debts did not give him standing to assert individual claims against the directors of the corporation where the shareholder was not seeking to enforce any specific obligations owed to him under the terms of the guarantee holding that the code excepts from discharge debts resulting from agreements by the debtor to hold the debtors spouse harmless on joint debts to the extent those debts are in the nature of alimony maintenance or support holding that when one corporation transfers its assets to another the receiving corporation is not responsible for debts of transferor unless it agrees to assume these debts holding that resident shareholder of s corporation is eligible for tax credit for taxes paid by corporation in another state and noting that this conclusion is consistent with the internal revenue code which provides that shareholders of an s corporation are entitled to a foreign tax credit for their share of foreign income tax paid by an s corporation holding that secretary of treasury may set off tax overpayments against debts owed to the commodity credit corporation