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behalf of petitioners in this Court.
In view of the evidentiary shortcomings in the record, we
cannot conclude that Mr. Wilde has the requisite capacity to file
a petition on behalf of petitioners.3 We therefore shall grant
respondent’s motion.
To the extent not herein discussed, we have considered
petitioners’ other arguments and consider them to be without
merit.
To reflect the foregoing,
An appropriate order of
dismissal will be entered.
3 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, Jimmy C. Chisum, who is listed as cotrustee in
the minutes submitted by petitioners 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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Last modified: May 25, 2011