Pasadena ENT Clinic, P.A. - Page 4

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          Through Dr. Izen, petitioner provides ear, nose, and throat                 
          medical services in a clinic located in Pasadena, Texas, its                
          principal place of business.                                                
               The parties have attached as exhibits to the stipulation:              
          (1) A copy of an order of involuntary dissolution of petitioner;            
          and (2) a copy of a letter from the Texas Secretary of State to             
          Dr. Izen dated December 17, 1984, declaring petitioner's                    
          involuntary dissolution due to its failure to file an annual                
          statement for the year 1984 as required by section 21 of the                
          Texas Professional Association Act, Tex. Civ. Stat. Ann. art.               
          1528f (West 1980).                                                          
          Discussion                                                                  
               Rule 60, Tax Court Rules of Practice and Procedure, provides           
          that the capacity of a corporation to engage in litigation in               
          this Court shall be determined by the law under which the                   
          corporation was organized.  See, e.g., Brannon's of Shawnee, Inc.           
          v. Commissioner, 71 T.C. 108, 111 (1978).                                   
               Petitioner's Dissolution                                               
               Under the facts of this case, petitioner's corporate                   
          existence is governed by two separate but interrelated Texas                
          statutes.  Section 25 of the Texas Professional Association Act,            
          Tex. Civ. Stat. Ann. art. 1528(f) (West 1980) provides that:                
               The Texas Business Corporation Act shall be applicable                 
               to professional associations, except to the extent that                
               the provisions of the Texas Business Corporation Act                   
               conflict with the provisions of this Act; and                          
               professional associations shall enjoy the powers and                   




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