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in the Rosenberg Case v. Commissioner, 27 T.C. 837, 839 (1957),
by establishing affirmatively all facts giving rise to our
jurisdiction, see Wheeler's Peachtree Pharmacy, Inc. v. Commis-
sioner, 35 T.C. 177, 180 (1960); Consolidated Cos., Inc. v.
Commissioner, 15 B.T.A. 645, 651 (1929). In order to meet that
burden, each petitioner must provide evidence establishing that
Mr. Chisum has authority to act on its behalf. See National
Comm. to Secure Justice in the Rosenberg Case v. Commissioner,
supra at 839-840; Coca-Cola Bottling Co. v. Commissioner, 22
B.T.A. 686, 700 (1931). We reject petitioners' position that
under Arizona law the validity of the purported appointment of
Mr. Chisum as trustee of each petitioner falls within the exclu-
sive jurisdiction of the courts of the State of Arizona.
On the record before us, we find that each petitioner has
failed to establish that Mr. Chisum is authorized to act on its
behalf.4
To reflect the foregoing,
An order of dismissal for lack
of jurisdiction granting respon-
dent’s motion will be entered.
4We have considered all of the contentions and arguments of
petitioners that are not discussed herein, and we find them to be
without merit and/or irrelevant.
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