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Trust Cases
As a preliminary matter, we must decide whether we should
dismiss the four cases in which the taxpayer is a trust.2 When
these consolidated cases were recalled from the calendar of the
trial session of this Court commencing on June 5, 2000, in
San Francisco, California, the Court, on its own motion,
questioned its jurisdiction to consider the petitions relating to
Caralan Trust and Alexion Trust because of the lack of a proper
party before the Court. Respondent moved to dismiss for lack of
jurisdiction with respect to C E Shirley Trust and Congo Trust.
On June 14, 2000, following proceedings in which counsel
established Ivan Oviedo, Joseph Shirley, and Curtis Shirley as
trustees for Caralan Trust, C E Shirley Trust, and Alexion Trust,
respectively, and we concluded that we did have jurisdiction in
those cases, we ordered that one motion for substitutions of
parties and changes of caption be made with respect to such
trusts. Such motion was due on July 14, 2000. Also on June 14,
2000, the Court ordered that a motion for substitution of party
and change of caption be made with respect to Congo Trust, such
motion to be accompanied by a memorandum of law setting forth the
grounds for establishing the substituted party as a trustee.
Such motion and memorandum also were due on July 14, 2000.
Neither motion (nor the memorandum of law) was received as
2 Docket Nos. 10151-99, 10152-99, 17075-99, and 17076-99.
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