After respondent Nordic Village, Inc., filed a petition for relief under Chapter 11 of the Bankruptcy Code, one of its officers withdrew funds from the companys corporate account. He sent part of the money to the Internal Revenue Service (IRS), directing it to apply the funds against his individual tax liability, which it did. In a subsequent adversary proceeding, the Bankruptcy Court permitted Nordic Villages trustee to recover the transfer and entered a monetary judgment against the IRS. The District Court affirmed, as did the Court of Appeals, which rejected a jurisdictional defense that sovereign immunity barred the judgment.

Held:

1. Section 106(c) of the Code does not waive the United States sovereign immunity from an action seeking monetary recovery in bankruptcy. Pp. 32-37.

(a) Hoffman v. Connecticut Dept. of Income Maintenance, 492 U.S. 96, does not control this case, since the plurality and the dissent therein were evenly divided over the issue whether 106(c) authorizes a monetary recovery against a State, and since th