- 3 - On July 17, 2000, petitioner filed its response with the Court. The response attached a copy of a trust instrument for petitioner dated April 5, 1996, but did not list either the name of petitioner’s trustee or petitioner’s assets or liabilities as of the date of the response. Nor did the response set forth petitioner’s position as to respondent’s motion. Petitioner prayed in the response that the Court give it until July 25, 2000, to comply with our Order. We granted petitioner’s prayer, ordering it to file with the Court a supplement to its response by July 26, 2000.3 Petitioner never filed such a supplement with the Court, and it never requested a further extension of time in order to do so. Respondent filed with the Court on August 2, 2000, a reply to petitioner’s response. We must decide whether to grant respondent’s motion. We are a legislatively created (Article I) Court, and, consequently, our jurisdiction flows directly from Congress. See Freytag v. Commissioner, 501 U.S. 868, 870 (1991); Neilson v. Commissioner, 94 T.C. 1, 9 (1990); Naftel v. Commissioner, 85 T.C. 527, 529 (1985); see also sec. 7442. Jurisdiction must be shown affirmatively, and petitioner, as the party desiring to invoke our jurisdiction, must establish affirmatively all facts giving 3 In addition to our regular service of process, we telephoned petitioner’s counsel on July 24, 2000, to inform them of this extension.Page: Previous 1 2 3 4 5 6 7 Next
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