- 3 - Petitioners timely filed a petition contesting respondent’s determination in the deficiency notice. At the time petitioners filed their joint petition, petitioners resided in Oklahoma City, Oklahoma. Attorney Frederick J. O’Laughlin (counsel) represented both petitioners in the deficiency proceeding. Respondent filed a motion for summary judgment (summary judgment motion) on May 7, 2002, involving all issues set forth in the deficiency notice. Respondent asserted in the summary judgment motion that petitioners were not entitled, as a matter of law, to deduct gambling losses in excess of gambling income under section 165(d). On the date petitioners were ordered to file a response to respondent’s summary judgment motion, petitioners’ counsel filed a motion to withdraw as counsel for Tomi, because petitioners had since divorced and their divorce created a conflict of interest. Along with the motion to withdraw, counsel filed, on behalf of both petitioners, a response to respondent’s summary judgment motion. The Court granted counsel’s motion for leave to withdraw as counsel for Tomi.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011