- 3 - B. Martin v. Commissioner, T.C. Memo. 2000-187 In 1986, respondent issued a notice of deficiency to Martin denying his Elektra/Hemisphere deductions for 1981 and 1982 and determining a deficiency. Respondent also issued a notice of deficiency to Rothhammer for 1981 and another for 1982 denying her Elektra/Hemisphere deductions for those years. Attorney Robert Bergman (Bergman) filed a petition on behalf of Martin and Rothhammer in docket No. 32146-86.4 Attorney Jeffrey Berg (Berg), who was a member of Bergman’s law firm, entered his appearance in docket No. 32146-86 in November 1986.5 In 1988, respondent issued a notice of deficiency to Martin and a second one to Rothhammer denying their Elektra/Hemisphere deductions for 1980. Berg signed and filed a petition in this case, docket No. 22961-88, in Rothhammer’s and Martin’s name. Berg attached Rothhammer’s, but not Martin’s, notice of deficiency to the petition. Martin contended that the 1988 petition was invalid as to him because he did not authorize or ratify the filing of the petition. Respondent contended that the petition was valid as to Martin because he authorized Berg to sign and file the petition 4 Amilu Rothhammer was dismissed from docket No. 32146-86 on Sept. 30, 1988, for lack of jurisdiction, because she and Martin had filed separate petitions disputing deficiencies for 1981 and 1982. 5 Jeffrey Berg was allowed to withdraw as counsel in docket No. 32146-86 on Jan. 26, 1989.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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