A February 16, 2021 decision of the United States District Court for the Southern District of New York held, in In re Citibank August 11, 2020 Wire Transfers, 520 F. Supp. 3d 390, that lenders who received almost $900 million mistakenly wired to them by Citibank (the administrative agent for a $1.8-billion syndicated seven-year term loan to Revlon [2016 Loan]) were entitled to keep the money.

Facts: The appellants were brothers who had incorporated a company (the “Corporation”) which was, in January 2008, involuntarily dissolved for failure to file corporate tax returns as required. In 2014, the minister issued an assessment under section 160 Notice of Assessment against the appellants.