- 9 - In view of the evidentiary shortcomings in the record, we find that Mr. Wilde has failed to establish the requisite capacity to file a petition on behalf of petitioner in this Court.5 We therefore shall grant respondent’s motion. To the extent not herein discussed, we have considered petitioner’s other arguments and find them to be without merit. To reflect the foregoing, An appropriate order of dismissal will be entered. 5 We note that Mr. Wilde is no stranger to this Court. Recently, in addition to the petition in Renaissance Enters. Trust v. Commissioner, T.C. Memo. 2000-226, mentioned earlier, Mr. Wilde filed petitions in Scenic Wonders Gallery, LLC v. Commissioner, T.C. Memo. 2000-64, and Photo Art Mktg. Trust v. Commissioner, T.C. Memo. 2000-65. In those cases, we granted the Commissioner’s motions to dismiss for lack of jurisdiction on the ground that Mr. Wilde lacked the requisite capacity to file petitions on behalf of those taxpayers. Additionally, Mr. Chisum, who is listed as cotrustee in the minutes and certification submitted by petitioner in the instant case, has filed petitions in at least three similar cases where motions to dismiss for lack of jurisdiction were granted on similar grounds. See Banana Moon Trust v. Commissioner, T.C. Memo. 2000-73 (holding Mr. Chisum did not have the requisite capacity to file a petition on behalf of the taxpayers); Jeff Burger Prods., LLC v. Commissioner, T.C. Memo. 2000-72 (similar holding); Bantam Domestic Trust v. Commissioner, T.C. Memo. 2000- 63 (similar holding).Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011