The question presented in this case is: Whether a bankruptcy trustee may avoid a debtor's tax payment to the United States under Section 544(b) when no actual creditor could have obtained relief under the applicable state  fraudulent-transfer law outside of bankruptcy.

The Supreme Court held: Section 106(a)’s sovereign-immunity waiver applies only to a §544(b) claim itself and not to state-law claims nested within that fed­eral claim.