Pat Smith Quoted in Tax Notes on Sixth Circuit’s Denial of Petition for Rehearing En Banc on Anti-Injunction Act Issue in CIC Services CasePDF
IPB attorney Pat Smith was quoted in a Tax Notes article on the Sixth Circuit’s denial of the plaintiff’s petition for rehearing en banc in the CIC Services case. Appeals Court Won’t Revisit Microcaptive Case in Close Call.
“Short of an actual overruling of the panel decision, this is about as good as CIC Services might have hoped for, with seven judges dissenting from the denial of rehearing en banc,” Patrick J. Smith of Ivins, Phillips & Barker Chtd. told Tax Notes.
“The substantial dissent should provide an excellent platform for CIC Services to file a very strong cert petition to the Supreme Court,” Smith added.