Starvest U.S., Inc. - Page 7




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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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