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marjac

06/08/20 10:25 PM

#279066 RE: MNBioMike #279064

MN, I can see it making a difference in those IRS matters which involve intense negotiation and ongoing comprehensive personal contact. Absolutely. Here, however, the Panel will literally read two Briefs from Singer, and hear 15 minutes of oral argument, so whether attorneys at his firm have some sort of relationship with the judges on the Panel, is of little import, as there is no opportunity for the type of intensive interaction that there is in those IRS matters.

And while it may happen at times, it would be completely inappropriate and sanctionable for both the attorney and the judge, if there was contact discussing this Appeal outside of those narrow confines.