Pasadena ENT Clinic, P.A. - Page 11

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          Conclusion                                                                  
               Having considered all of petitioner's arguments, we find               
          them to be without merit.  We hold that petitioner lacked the               
          capacity under Rule 60(c) to file a petition in this Court, and             
          we will grant respondent's motion to dismiss for lack of                    
          jurisdiction.  See Condo v. Commissioner, 69 T.C. 149 (1977); Lee           
          Enterprises, Inc. v. Commissioner, T.C. Memo. 1992-629.  The                
          liabilities at issue here may be litigated on their merits in the           
          event respondent should issue a notice of transferee liability to           
          the appropriate person.  Sec. 6901; Great Falls Bonding Agency,             
          Inc. v. Commissioner, supra at 307.                                         
               An order and order of dismissal                                        
          will be entered.                                                            
























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