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First, as noted, an application for a writ of certiorari was filed, and the Supreme Court vacated the Ninth Circuit's decision and remanded the case for reconsideration in light of Christensen. Second, the Ninth Circuit as well as a number of Ninth Circuit judges seem to take the view that Rennae v. Hawk is overruled by the Supreme Court's decision in Clark. [7] The Fifth Circuit also cited pre-Clark decisions from other Circuits, including: Goodwin v. Johnson, 132 F.3d 166, 175 n. 5 (5th Cir.1998); and Camp v. Lewis, 644 F.2d 5, 8 (9th Cir.1980). See Ventura, 332 F.3d at 1261. The Sixth Circuit, in addition, cited a decision of the Eighth Circuit, which is no longer good law. See Sec. & Exch. Comm'n v. Smith, 976 F.2d 1021, 1028 (6th Cir.1992). [8] As noted, the Fifth Circuit's decision in Ventura addressed the issue of whether the IRS must follow the disclosure procedures of the administrative due process provisions of the Internal Revenue Code. See 537 F.3d at 344. 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