Bankruptcy exemptions are available only to individuals filing bankruptcy. In 1998, Novartis filed international patent applications claiming priority to the 1997 filing. This often happens with companies that are on the verge of filing for bankruptcy. He also orchestrated an involuntary bankruptcy filing by several small Ponzi investors. The tax rate and some deductions are different for individuals depending on filing status. The investigation led to Tyco filing two federal lawsuits. Some jurisdictions permit or require electronic filing of returns. The income level at which various tax rates apply for individuals varies by filing status. However, it did uphold its requirement for income tax filing and welfare programmes. These were all specific items of contention brought to the court in the 2005 filing. Any procedures applicable to the filing of arguments must also be followed. Notifications of dates and schedules of election for filing nominations are issued by the commission. In 2009, 70% of filers qualified for free electronic filing of federal returns. Apple countersued by filing a complaint with the ITC in January 2010. The Kodak patent filing was earlier.