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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.
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Last modified: May 25, 2011