Key legal question
Whether the challenged judges and court clerk had to recuse themselves because of prior involvement in related tax proceedings
Extracted holding
Prior participation in earlier proceedings on the same matter did not, by itself, create an appearance of bias; no additional circumstances showing prejudice were established.
Extracted reasoning
A judge is not biased merely because the case returns in a new procedure or because the court previously decided against a party. The new proceeding concerned correction of defects from the earlier process and was not materially different from a remittal-type situation; the same applies analogously. The earlier security proceeding also involved different questions and did not definitively decide the tax claim.