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claimed to have authority to act on Starvest's behalf, Mr. de
Bruijn now claimed that he was not and had never been an officer
or director of Starvest. Gibbs further represented that his firm
had not had contact with any party related to petitioner other
than de Bruijn and did not name any individual or party who had
authority to represent Starvest.
On July 2, 1998, respondent filed a motion to dismiss for
lack of jurisdiction in docket No. 16948-97 with respect to the
1997 notice of deficiency on the grounds that petitioner did not
have the capacity to initiate the action because it was
dissolved, and petitioner had not authorized any person to
initiate such litigation.
Jacques de Bruijn then retained the law firm of Ruden,
McClosky, et al. (Ruden) to represent Starvest in matters
relating to the 1997 notice of deficiency. On August 6, 1998,
Ruden filed an opposition to respondent's motion to dismiss.
Then, on August 11, 1998, Ruden filed a motion to dismiss for
lack of jurisdiction on the grounds that the 1997 notice of
deficiency had not been sent to petitioner's last known address.
On November 4, 1998, Ruden filed a motion to withdraw as counsel
for Starvest. In this motion, counsel represented that Starvest
could be contacted at (1) Tivoliweg 85B, 4561 HK Hulst,
Netherlands, and (2) care of Jacques de Bruijn, 472 First Street
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