Lyndon D. Sinele - Page 1

                                 T.C. Memo. 2004-137                                  


                               UNITED STATES TAX COURT                                


                           LYNDON D. SINELE, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 7801-02.            Filed June 10, 2004.                    

               Jerrold N. Arnowitz (specially recognized) and John L.                 
          Hause (specially recognized), for petitioner.1                              
               D. Sean McMahon, for respondent.                                       


               1  At calendar call, Mr. Arnowitz and Mr. Hause advised the            
          Court that they had just been retained by petitioner.  The Court            
          asked if they were admitted to practice before the Court.  Mr.              
          Arnowitz and Mr. Hause advised the Court that although they were            
          admitted to practice in Massachusetts, they were in the process             
          of being admitted to the Court.  Between calendar call and the              
          trial, both Mr. Arnowitz and Mr. Hause were admitted to practice            
          before the Court.  At trial, Mr. Hause appeared on behalf of                
          petitioner.                                                                 
               Subsequent to the trial, petitioner filed two motions to               
          extend time to file his opening brief.  In the motions, he stated           
          that he could no longer afford Mr. Arnowitz and Mr. Hause and               
          they no longer represented him.  It is unclear, however, whether            
          Mr. Arnowitz and Mr. Hause represented petitioner during the                
          briefing period as Mr. Arnowitz and Mr. Hause have not filed a              
          motion to withdraw as counsel and no briefs were filed by                   
          petitioner.                                                                 


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