The Fifth Circuit refused a petition for rehearing en banc, 10 - 7, in the Goldring case. That left intact the Fifth Circuit's taxpayer-favorable ruling on interest treatment of "rolling credit elect transfers." That, in tern, establishes a circuit split between the Fifth Circuit and the Federal Circuit's decision in FleetBoston. Will the government file a petition for writ of certiorari with the Supreme Court? The IRS says there are a lot more taxpayers with similar fact patterns, and the interpretation by the Fifth Circuit arguably contradicts both the DOJ Tax Division's position on the "use of money" principle and Congress's direction in the global interest netting regime of section 6621(d). But the Supreme Court doesn't really enjoy tax cases.