Opinion for the Court filed by Chief Judge MIKVA.
MIKVA, Chief Judge:
This appeal concerns a dispute between the IRS and two partnerships over assets that the IRS seized from Mr. Edward Markowitz, the partnerships' errant former general partner. The partnerships claim that the seized assets are rightfully partnership property, rather than personal property of Markowitz, and are therefore not subject to seizure for purposes of satisfying Markowitz's personal...
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