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case, petitioner has the burden of proving that this Court has
jurisdiction, see Fehrs v. Commissioner, 65 T.C. 346, 348 (1975);
National Comm. to Secure Justice in the Rosenberg Case v. Commis-
sioner, 27 T.C. 837, 839 (1957), by establishing affirmatively
all facts giving rise to our jurisdiction, see Wheeler's
Peachtree Pharmacy, Inc. v. Commissioner, 35 T.C. 177, 180
(1960); Consolidated Cos., Inc. v. Commissioner, 15 B.T.A. 645,
651 (1929). In order to meet that burden, petitioner must
provide evidence establishing that Mr. Wilde and Mr. Chisum have
authority to act on its behalf.5 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 petitioner’s position that the validity of the
purported appointment of Mr. Wilde and Mr. Chisum as trustees of
petitioner falls within the exclusive jurisdiction of the Supe-
rior Court of the State of Arizona.
5Petitioner no longer contends that Mr. Chisum is authorized
to act on its behalf in this proceeding as the agent of Prudent
Man Trustee Co., and we conclude that it has abandoned any such
argument. Even if it had not abandoned such an argument, on the
record before us, we find that petitioner has not shown that Mr.
Chisum was properly employed by the trustee of petitioner in
accordance with the laws of either the State of Arizona, see
Ariz. Rev. Stat. Ann. sec. 14-7233.C.24. (West 1995), or the
State of Indiana, see Ind. Code Ann. sec. 30-4-3-3(a)(16) (Michie
1989). We further find that, unless Mr. Chisum is a duly ap-
pointed and authorized trustee of petitioner, Mr. Chisum is not
authorized to represent or act in this proceeding on behalf of
either petitioner or the trustee of petitioner. See Rules 60,
200.
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