Nos. 05-3260, 05-3518.

492 F.3d 806 (2007)

UNITED STATES of America, Petitioner-Appellant, Cross-Appellee, v. BDO SEIDMAN, LLP, regarding IRS examination of BDO Seidman, LLP, Respondent-Appellee, and Robert S. Cuillo, et al., Intervenors-Appellees, Cross-Appellants.

United States Court of Appeals, Seventh Circuit.

Decided July 2, 2007.

Attorney(s) appearing for the Case

Frank P. Cihlar (argued), Karen D. Utiger, Michelle B. Smalling, Department of Justice, Tax Division, Appellate Section, Washington, DC, for Petitioner-Appellant.

Cary B. Samowitz (argued), DLA Piper US LLP, New York, NY, Michael S. Poulos, DLA Piper US LLP, Chicago, IL, for Respondent-Appellee.

George W. Connelly, Juan F. Vasquez, Jr., Chamberlain, Hrdlicka, White, Johnson & Williams, Houston, TX, David D. Aughtry (argued), Chamberlain, Hrdlicka, White, Williams & Martin, Atlanta, GA, for Intervenors-Appellees.

Before RIPPLE, KANNE and WILLIAMS, Circuit Judges.

RIPPLE, Circuit Judge.

This is the third appeal arising out of an effort by the Internal Revenue Service ("IRS") to enforce administrative summonses against BDO Seidman, LLP ("BDO"), an accounting firm that allegedly failed to disclose potentially abusive tax shelters that it promoted. See United States v. BDO Seidman, 337 F.3d 802 (7th Cir.2003) (BDO II); United States v. BDO Seidman, Nos. 02-3914 & 02-3915...


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