- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
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