United States Third Circuit

An interlocutory appeal prior to Tax Court rulings on unresolved issues is not permissible because it is essentially a request for an advisory opinion forbidden by Article III of the Constitution.

Appellate Information

• Argued 01/19/2001
• Decided 05/01/2001
• Published 05/01/2001

Judges

• Before ROTH and BARRY, Circuit Judges, SHADUR, District Judge.

Court

• United States Third Circuit

Counsel

• For Appellant:
  
• William F. Nelson (argued), Gerald A. Kafka, J. Bradford Anwyll, McKee Nelson Ernst & Young, LLP, Washington, DC, Attorneys for Appellant.


• For Appellees:
  
• Charles F. Marshall (argued), Paula M. Junghans, Richard Farber, Tax Division, Department of Justice, Washington, DC, Attorneys for Appellee.