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(1975); National Comm. to Secure Justice in the Rosenberg Case v.
Commissioner, 27 T.C. 837, 839 (1957), by establishing affirma-
tively all facts giving rise to our jurisdiction, 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, each petitioner must
provide evidence establishing that Mr. Wilde has 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
reject petitioners' position that under Arizona law the validity
of the purported appointment of Mr. Wilde as co-trustee of each
petitioner falls within the exclusive jurisdiction of the courts
of the State of Arizona.
On the record before us, we find that each petitioner has
failed to establish that Mr. Wilde is authorized to act on its
behalf.3
To reflect the foregoing,
An order of dismissal for lack
of jurisdiction granting respon-
dent’s motion will be entered.
3We have considered all of the contentions and arguments of
petitioners that are not discussed herein, and we find them to be
without merit and/or irrelevant.
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