Quantum Investments, L.L.C. - Page 9




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               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).                                                       





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