SEVEN W. ENTERPRISES AND SUBSIDIARIES v. C.I.R.

Nos. 12-2099, 12-2100.

723 F.3d 857 (2013)

SEVEN W. ENTERPRISES, INC. AND SUBSIDIARIES and Highland Supply Corporation and Subsidiaries, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Seventh Circuit.

Decided July 24, 2013.


Attorney(s) appearing for the Case

Philip D. Speicher (argued), Attorney, Mathis Marifian & Richter Ltd., Belleville, IL, for Petitioners-Appellants.

Patricia McDonald Bowman (argued), Attorney, Robert W. Metzler , Gilbert S. Rothenberg , Deputy Assistant Attorney General, Department of Justice, Office of the Attorney General, Washington, DC, for Respondent-Appellee.

Before RIPPLE and TINDER, Circuit Judges, and ZAGEL, District Judge.


RIPPLE, Circuit Judge.

Seven W. Enterprises, Inc. and Subsidiaries ("Seven W") and Highland Supply Corporation and Subsidiaries ("Highland") (collectively "the Taxpayers") filed petitions for redetermination with the United States Tax Court. The petitions were consolidated for trial, and the Tax Court issued a decision with respect to each petition. Those decisions, however, inadvertently attributed Seven W's tax liability to Highland, and Highland's tax liability...

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