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all facts giving rise to our jurisdiction, see Wheeler's Peach-
tree 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. Chisum has authority to act on
behalf of Banana Moon Trust, the purported TMP of Jeff Burger
Productions. See National Comm. to Secure Justice in the Rosen-
berg 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 under Arizona law the validity of the
purported appointment of Mr. Chisum as the trustee of Banana Moon
Trust falls within the exclusive jurisdiction of the courts of
the State of Arizona.
On the record before us, we find that petitioner has failed
to establish that Mr. Chisum is authorized to act on behalf of
Banana Moon Trust, the purported TMP of Jeff Burger Productions.4
4We 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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