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T.C. Memo. 2000-226, wherein Mr. Wilde claimed that he was
appointed trustee by the resigning trustee, Stern & Stein. In
Renaissance Enters. Trust, Mr. Wilde submitted minutes from Stern
& Stein as proof of his appointment which mirror the minutes
submitted in this case except for the title on the top of the
document. It appears that Mr. Wilde simply copied the minutes
submitted in Renaissance Enters. Trust and submitted them as
Morgan, Kramer’s minutes in the present case. We therefore
question the authenticity of the minutes.
At the hearing, Mr. Wilde submitted on behalf of petitioner
the certification and the purported trust document.4 Petitioner
alleges that the certification and the purported trust document
attest to the chain of petitioner’s trustees and show that Mr.
Wilde is a current trustee of petitioner. The purported trust
document is incomplete, and when both it and the certification
are viewed in light of the questionable minutes submitted by Mr.
Wilde, we are not persuaded by these documents that Mr. Wilde is
the duly appointed and authorized trustee of petitioner.
4 In Troy Enters. Trust v. Commissioner, T.C. Memo. 2000-
227, which we recently decided, the Commissioner filed a motion
to dismiss for lack of jurisdiction based on the Commissioner’s
assertion that Mr. Wilde was not a trustee of Troy Enterprises
Trust or Yale Enterprises Trust. In Troy Enters. Trust, we held
that Mr. Wilde did not have the requisite capacity to file a
petition on behalf of Troy Enterprises Trust and Yale Enterprises
Trust. In that case, however, the certification and purported
trust document were not part of the record. Because those
documents are part of the record in the instant case, we review
them in making our determination in this case.
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