- 2 - Karen J. Goheen, for respondent. MEMORANDUM OPINION DAWSON, Judge: This case was assigned to Special Trial Judge D. Irvin Couvillion pursuant to section 7443A(b)(4)and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below. OPINION OF THE SPECIAL TRIAL JUDGE COUVILLION, Special Trial Judge: Petitioner Maryn J. Dornbrock (Mrs. Dornbrock) has before the Court a motion for leave to file a motion to vacate or revise the decision that was entered in this case.2 This case is one of a group of cases that constituted a national litigation project identified by respondent as "IG-Phonomasters" and involved investors in a master recording leasing program. A joint petition was filed in this case on July 11, 1985, on behalf of numerous investors in this program, which included Roger W. Dornbrock and his wife, 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2 As discussed later in greater detail, this motion was filed by petitioner, Maryn J. Dornbrock, individually on her own behalf, and on behalf of the Estate of Roger W. Dornbrock, Deceased, in her capacity as personal representative of such estate.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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