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program, including Mr. and Mrs. Dornbrock.5 The timely petition
in this case was filed on behalf of petitioners by Hallison H.
Young (Mr. Young), an attorney who is admitted to practice
before this Court.6 At the time the petition was filed, Mr. and
Mrs. Dornbrock were legal residents of the State of Michigan. On
July 19, 1987, Mr. Dornbrock died, and Mrs. Dornbrock was
subsequently appointed as personal representative of his estate
by the Probate Court of Wayne County, Michigan. At the time the
subject motion was filed, Mrs. Dornbrock continued to be a legal
resident of the State of Michigan.
Due to the large number of participants in the Pop
Phonomasters program who had filed the joint petition, several
petitioners representing various versions of the program were
selected as "lead cases" that were tried first, and the remainder
of petitioners were severed from the lead cases and assigned a
separate docket number (i.e., this case). The Court then
continued this case pending the outcome of the lead cases. Roger
W. Dornbrock and Maryn J. Dornbrock were among petitioners who
5
For purposes of simplicity in numbers, the Court counts
husbands and wives who filed joint returns and received joint
notices of deficiency as "one" petitioner.
6
The petition was signed by Mr. Young as counsel for
petitioners. A petition in the Tax Court need not be signed by
the taxpayers and may be signed by their counsel. Rules
23(a)(3), 24(a).
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