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IN RE CROWELL

No. 01-5374.

305 F.3d 474 (2002)

In re Larry CROWELL and Mary S. Crowell, Debtors. Larry Crowell, Mary S. Crowell, Duane C. Olcsvary, and Patricia C. Olcsvary, Appellants, v. United States of America and Internal Revenue Service, Appellees.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: September 18, 2002.

Attorney(s) appearing for the Case

Kyle R. Weems (argued and briefed), Weems & Associates, Chattanooga, TN, for Appellants.

Jason S. Zarin, U.S. Dept. of Justice Tax Div., Washington, DC, Kenneth L. Greene (briefed), Karen D. Utiger (argued and briefed), U.S. Dept. of Justice, Appellate Section Tax Div., Washington, DC, for Appellees.

Before SUHRHEINRICH, SILER, and GILMAN, Circuit Judges.

OPINION

SILER, Circuit Judge.

Debtors Larry and Mary Crowell and Duane and Patricia Olcsvary appeal the ruling of the bankruptcy and district courts that Internal Revenue Service ("IRS") Delegation Order ("DO") 209 applies to their agreements with the IRS settling the tax treatment of certain partnership items. Because DO 209 deals specifically with delegated authority to enter into written settlement agreements in partnership cases, as opposed to the more...

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