- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011