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S & O LIQUIDATING PARTNERSHIP v. C.I.R.

No. 01-1631.

291 F.3d 454 (2002)

S & O LIQUIDATING PARTNERSHIP, et al., Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Appeals of David BEACH, Robert M. Berliner, Jay I. Borow, et al.

United States Court of Appeals, Seventh Circuit.

Decided May 23, 2002.

Attorney(s) appearing for the Case

Helayne O. Stoopack, Kramer, Levin, Naftalis, Nessen, Kamin & Frankel, New York, NY, for Petitioners-Appellees.

Stuart L. Brown, IRS, Washington, DC, Gary R. Allen, Joan I. Oppenheimer (argued), DOJ, Tax Div., App. Sec., Washington, DC, William F. Hammack, IRS, Dallas, TX, for Respondent-Appellee.

Joseph J. Haspel (argued), Stein, Riso & Mantel, New City, NY, for Appellants.

Isidore R. Tucker, New York, NY, for Appellee.

Before COFFEY, ROVNER and EVANS, Circuit Judges.

COFFEY, Circuit Judge.

The Tax Court permitted several former partners of the now-defunct accounting firm of Spicer & Oppenheim ("Spicer") to intervene and participate in a global settlement regarding the partnership's tax returns. The appellants, who are the original partners and signatories to the agreement, objected to the intervention but nonetheless signed closing agreements that resolved their disputes with the Commissioner prior to filing this appeal of...

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