We'll hear argument next in case 23-824, United States v. Miller.

Ms. Nguyen.

Mr. Chief Justice, and may I please the Court, the bankruptcy code grants trustees an

array of avoidance powers, including the power to avoid fraudulent transfers under

Section 548, subject to a two-year federal look-back period.

This trustee's claim is time-barred, so he's relied on a different code provision,

Section 544B.

But 544B has no application here.

That provision looks to whether a real-world creditor can avoid a transfer under state law

with a longer look-back period.

Rather than leave that right to one creditor,

Congress authorized the trustee to pull it into bankruptcy to benefit all creditors.

But 544B doesn't come into play unless a transfer is already voidable under state law.

544B simply allows the trustee to piggyback off that existing vulnerability.

In practice, that means 544B has a two-level structure.

The trustee must first identify a creditor with the right to avoid the transfer under state law.

If so, he can step into the creditor's shoes and avoid the same transfer under 544B.

But if not, he has no one's shoes

to step into and he can't use 544B to circumvent the code's two-year look-back period.

Here, any creditors attempt to avoid these federal taxes under state law would obviously

be barred by sovereign immunity and other obstacles. The trustees' parallel 544B action

should therefore fail on the merits. Respondent's main argument is that Section 106A

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