A Federal District Court judge has remanded to State court a lawsuit brought against Citigroup Inc. in which the relator contended that Citigroup had violated the New York False Claims Act by claiming net operating loss ("NOL") deductions despite its reliance on IRS notices supporting its position that sales of equity interests to the government under the Troubled Asset Relief Program did not reduce taxpayers' ability to use preexisting NOLs. State of New York ex rel. Eric Rasmusen, 15cv07826(LAK) (S.D.N.Y., Dec. 2, 2016). The court found that the action does not necessarily present substantial federal questions, since the relator lacks standing to challenge the validity of the IRS notices, and the question of whether New York follows federal law on determining the validity of NOL deductions is a question of state law. While noting that "New York interprets its tax laws in accord with federal law whenever possible," and describing the relator's argument to the contrary as having "dubious merit," the federal court found it lacked jurisdiction and remanded the case back to the State court from which it had been removed.