by the United States government, United States Code — Title 11, Chapter 5…
“ For the purpose of subsection (a) of this section, a claim of a governmental unit arising from an erroneous refund or credit of a tax has the same priority as a claim for the tax to which such refund or credit relates. (d) An entity that is subrogated to the rights of a holder of a claim of a kind specified in subsection (a) (1) , (a) (4) , (a) (5) , (a) (6) , (a) (7) , (a) (8) , or (a) (9) of this section is not subrogated to the right of the holder of such claim to priority under such subsection. ”
