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and repeated her claim that she, not Mr. Mansour, was WFO’s
proper representative in its case. We set a hearing to determine
the person authorized to represent WFO and to receive evidence
with respect to respondent’s Motion for Entry of Decisions.
FINDINGS OF FACT
Based upon the evidentiary hearing and the record in these
cases, we make the following findings of fact.
Mr. and Mrs. Wolfe resided in Cincinnati, Ohio, when they
filed their petitions. They were married at the time but
subsequently initiated divorce proceedings.
WFO had its principal place of business in Cincinnati, Ohio,
when it filed its petition. WFO is wholly owned by Mrs. Wolfe,
who serves as WFO’s president and signed WFO’s petition as its
representative. See Rule 24(b). WFO operates a club under the
trade name of Bristol’s.
I. Negotiations Leading to the Settlement
Trial in these cases was originally set for January 13,
2003, in Cincinnati, Ohio. Petitioners had retained Mr. Mansour,
a certified public accountant, to represent them before the
Internal Revenue Service, though Mr. Mansour did not sign any of
the petitions in these cases. However, as the trial date
approached, petitioners retained James F. McCarthy, III, as
counsel. Mr. McCarthy entered his appearance on behalf of Mr.
and Mrs. Wolfe and WFO at the calendar call on January 13, 2003,
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