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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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Last modified: May 25, 2011