Mark A. and Juanita D. Murdock - Page 7

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            neither Mr. Griffin nor Mr. Driscoll had received any notice or                            
            had knowledge that Mr. Griffin no longer represented petitioners                           
            or no longer had the authority to act for them as their attorney.                          
            The IRS Form 2848, Power of Attorney and Declaration of                                    
            Representative, which petitioners executed on December 29, 1993,                           
            was not received by counsel for respondent until February 14,                              
            1994.  The Form 2848 was accompanied by a letter signed by                                 
            petitioners, dated January 5, 1994, which stated in part:                                  

                        This letter is to certify that my wife and I disagree                          
                  with the decision (Docket No. 16255-92) that you and Mr.                             
                  Griffin has agreed upon.  Mr. Griffin is no longer                                   
                  hired/representing me nor can he enter into any contracts.                           
                  His Power of Attorney is no longer valid.  His signature on                          
                  the United States Tax Court Decision is invalid/void as of                           
                  the date he signed it.                                                               
                        I have decided that there is no tax due and will be                            
                  going to Tax Court on my behalf.  I have a number of                                 
                  witnesses and affidavits to win in Tax Court.                                        
                        Also I have not seen any figures, explanations, or                             
                  relevant reasons that the imposed tax is true and correct by                         
                  you or Mr. Griffin.                                                                  

                  The Court is satisfied from the evidence adduced at the                              
            hearing that, at the conference on January 5, 1994, petitioner                             
            raised no objection to a settlement of the case.  The purpose of                           
            the conference was to determine whether the case would settle, or                          
            whether the parties would proceed to trial.  The Court is                                  
            satisfied that Mr. Griffin, at the time of that conference and of                          
            the entry of decision, had no knowledge that petitioners desired                           
            to remove him as their attorney, nor did such information come to                          





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