- 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
Last modified: May 25, 2011