- 5 -
petition on behalf of Universal, contesting the notice sent to
Universal for 1993. See Universal Trust 06-15-90, Four WS TT01,
Trustee v. Commissioner, docket No. 3885-98 (Universal).
Due to the common issues involved, we granted respondent’s
motion to consolidate Ghavami and Universal with the case at
hand. Shortly before trial, however, respondent moved to dismiss
Universal for lack of jurisdiction, on the ground that Mr. Chisum
had failed to establish his capacity to file a petition on behalf
of Universal. Respondent also moved to sever Universal from the
consolidated case, and we granted that motion. Shortly
thereafter, Mr. Chisum submitted a motion to dismiss Universal on
various jurisdictional and procedural grounds. Because
respondent and Ms. Ghavami have agreed to a decision that there
is no deficiency in Ms. Ghavami’s tax for 1993, we have also
granted respondent’s motion to sever Ghavami from the case at
hand.
2(...continued)
known to this Court. See, e.g., Lipari v. Commissioner, T.C.
Memo. 2000-280 (sec. 6673 penalty imposed on taxpayers who
claimed they were unable to obtain records from Mr. Chisum, the
“trustee” of their “trust”); Banana Moon Trust v. Commissioner,
T.C. Memo. 2000-73 (dismissed for lack of jurisdiction because
Mr. Chisum, who claimed to be “trustee”, did not have capacity to
file petition); Jeff Burger Prods., LLC v. Commissioner, T.C.
Memo. 2000-72; Bantam Domestic Trust v. Commissioner, T.C. Memo.
2000-63; Photo Art Mktg. Trust v. Commissioner, T.C. Memo. 2000-
57; George v. Commissioner, T.C. Memo. 1999-381 (“trust” of which
Mr. Chisum was “trustee” was a sham, and payments received by
that “trust” were income of osteopathic physician who performed
services that generated the income).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011