Court of Appeals for the Third Circuit May 1, 2001, 00-3636 (Rhone-Poulenc Surfactants And Specialties, L.P. v. Commissioner Of Internal Revenue)

249 F.3d 175 (3rd Cir. 2001) RHONE-POULENC SURFACTANTS AND SPECIALTIES, L.P., GAF CHEMICALS CORPORATION, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee No. 00-3636 UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT Argued January 19, 2001 Opinion Filed May 1, 2001 William F. Nelson, Esq. (argued), Gerald A. Kafka, Esq., J.