- 13 -
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 and Mr. Chisum have
authority to act on its behalf.3 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 and Mr.
Chisum as trustees of each petitioner falls within the exclusive
jurisdiction of the State of Arizona.
We are not persuaded by the respective documents relating to
petitioners entitled “APPOINTMENT OF SUCCESSOR TRUSTEE” and
“MINUTE OF TRUSTEE RESIGNATION” that Mr. Wilde and Mr. Chisum are
3Petitioners no longer contend that Mr. Chisum is authorized
to act on their behalf in this proceeding as the agent of D & E
Sword Co., and we conclude that they have abandoned any such
argument. Even if they had not abandoned such an argument, on
the record before us, we find that petitioners have not shown
that Mr. Chisum was properly employed by the trustee of each
petitioner in accordance with the laws of the State of Arizona.
See Ariz. Rev. Stat. Ann. sec. 14-7233.C.24. (West 1995). We
further find that, unless Mr. Chisum is a duly appointed and
authorized trustee of each petitioner, Mr. Chisum is not auth-
orized to represent or act in this proceeding on behalf of either
each petitioner or the trustee of each petitioner. See Rules 60
and 200.
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