In the Goldring case, the Fifth Circuit reversed the decision by the Eastern District of Louisiana and held that the taxpayers were no liable for underpayment interest for the year at issue when the government held sufficient funds to pay the deficiency in other years. This was a complex issue involving "rolling credit elect transfers," where the taxpayer paid more to the government than its reported tax liability for that year, and then chose to have the excess applied to its estimated taxes for the following year - for multiple years in succession. The fact pattern went beyond the normal situation for which the IRS grants interest relief and the Fifth Circuit's decision was contrary to the Federal Circuit's decision in FleetBoston. The Fifth Circuit's explanation for the decision was not convincing, but we now have a circuit split. The government requested a rehearing en hanc.