WILMINGTON, Del. - Bankrupt solar energy company Solyndra LLC on Oct. 15 filed a brief in the U.S. Bankruptcy Court for the District of Delaware supporting the confirmation of its Chapter 11 plan contending that the U.S. Department of Energy (DOE) lacks claims for diminution and the IRS cannot show that the plan's purpose is tax avoidance (In Re: Solyndra LLC, No. 11-12799, Chapter 11, D. Del. Bkcy.).