United States Bankruptcy Court, D. Delaware October 8, 2013, Case No. 08-13041(CSS) Jointly Administered; Adv. Proc. No. 10-53731(CSS) (Giuliano v. Federal Deposit Insurance (In re Downey Financial Corp.))

Chapter 7

RE: Adv. Docket Nos.: 79 and 81

OPINION

1

Sontchi, J.

INTRODUCTION

This matter requires the Court to determine whether a substantial tax refund is property of the estate due to a tax sharing agreement between the debtor, Downey Financing Corp. (“DFC” or the “Debtor”), and its non-debtor subsidiary, Downey Savings and Loan Association, F.A. (“Dow-ney Bank”).