United States ex rel. Internal Revenue Service v. Galletti

ORDER AND AMENDED OPINION

ORDER

The opinion filed August 8, 2002, 298 F. 3d 1107, is amended as follows:

On slip opinion page 11556, just before the summary paragraph, add the following two paragraphs:

In its petition for rehearing, the IRS asserts that the Seventh Circuit has held that the IRS can bring suit against individual partners, and obtain a judgment against them, for as long as the tax obligations remain a valid debt of the partnership, citing United States v. Wright, 57 F.3d 561 (7th Cir.1995). Wright is distinguishable because, in that case, the IRS had assessed both the partnership…