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the medical corps. While in the Navy, he spent about 6 months
each year at sea on dates not stated in the record. At a date
not stated in the record, he moved to Rockville, Maryland, and
became Chief of Vascular Surgery at Bethesda Naval Hospital. In
1986 he left active duty and moved to Suffolk, Virginia, where he
practiced medicine until 1993.
Petitioner hired Arthur Robb (Robb), a certified public
accountant, to prepare his income tax returns, when he moved to
Suffolk, Virginia. Petitioner signed a Form 2848, in which he
authorized Robb to represent him before the IRS. Petitioner
never authorized Robb to hire an attorney for him.
In 1993, petitioner moved to Santa Fe, New Mexico, and began
a solo practice in general thoracic and vascular surgery.
B. The Partnerships in Which Petitioner Invested and Counsel
for Those Partnerships
Before 1980, 1981, and 1982, petitioner and Rothhammer
bought limited partnership interests in Winchester Oil, Synergy
Resources, and other partnerships. Winchester Oil was one of the
Manhattan group partnerships (Manhattan). Manhattan was a group
of 20 partnerships which were involved in the Elektra-Hemisphere
cases tried by this Court. The general partners of Manhattan
hired the law firm of Zobrist, Vienna & McCullough (Zobrist) to
file petitions at the request of any of the limited partners.
Attorneys Michael Matthias (Matthias) and Jeffrey Berg (Berg),
and paralegal Bruce Morton (Morton), handled the Manhattan cases
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