- 8 - 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).3 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 petitioner has failed to establish that either Mr. Slagle or Mr. Buchanan is authorized to act on its behalf.4 To reflect the foregoing, An order of dismissal for lack of jurisdiction granting respon- dent’s motion will be entered. 3Nor has petitioner introduced into the record any other documentary evidence establishing who the first appointed trustee of petitioner was. 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.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011