SIH PARTNERS LLLP v. COMMISSIONER OF INTERNAL REVENUE (2019)

SUR PETITION FOR REHEARING

The petition for rehearing filed by appellant, SIH Partners LLLP, Explorer Partner Corporation, Tax Matters Partner, in the above captioned matter having been submitted to the judges who participated in the decision of this Court and to all the other available circuit judges of the Court in regular active service, and no judge who concurred in the decision having asked for rehearing, and a majority of the circuit judges of the circuit in regular active service who are not disqualified not having voted for rehearing by the Court en banc, the petition for rehearing by the panel and the Court en banc is denied. Judge Greenberg’s vote is limited to denying rehearing before the original panel.

Morton I. Greenberg, Circuit Judge