As now-bankrupt bank's contractual agreement with its now-bankrupt affiliated group is incredibly complex and ambiguous, the provision of the agreement mandating that any ambiguities be construed in favor of the bank means that there was only an agency relationship between the bank and the organization and the latter has no equitable title to the tax refund due the affiliated organization; the refund now belongs to the bank's FDIC receiver.
https://www.ca10.uscourts.gov/opinions/17/17-1281.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.