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tion, 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. Slagle and Mr.
Buchanan have 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 are not persuaded by the various documents that are part
of the record, including the documents entitled “ACCEPTANCE OF
THE TRUST BY THE TRUSTEE”, that Mr. Slagle and Mr. Buchanan are
the duly appointed and authorized trustees of petitioner. In
this connection, it is significant that petitioner has not made
part of the record the complete trust documents for petitioner
(assuming such documents exist).4 Without such documents, we are
unable to determine whether the appointment of one or more
trustees is valid. On the record before us, we find that peti-
tioner has failed to establish that either Mr. Slagle or Mr.
Buchanan is authorized to act on its behalf.5
4Nor has petitioner introduced into the record any other
documentary evidence establishing who the first appointed trustee
of petitioner was.
5We have considered all of the contentions and arguments of
petitioner that are not discussed herein, and we find them to be
without merit and/or irrelevant.
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