T.C. Memo. 2000-390
UNITED STATES TAX COURT
UNIVERSAL TRUST 06-15-90, FOUR WS TT01,
TRUSTEE, Petitioner v. COMMISSIONER
OF INTERNAL REVENUE, Respondent
Docket No. 3885-98. Filed December 27, 2000.
Jimmy C. Chisum, for petitioner.1
Nicholas J. Richards and Miles D. Friedman, for respondent.
MEMORANDUM OPINION
BEGHE, Judge: This case is before the Court on the parties’
cross-motions to dismiss for lack of jurisdiction. Petitioner
asserts we must dismiss because respondent failed to determine a
1 As explained in the text, respondent challenges Mr.
Chisum’s capacity to conduct litigation on behalf of petitioner
in any capacity. Our tentative description of Mr. Chisum as
appearing for petitioner, and our ascribing of Mr. Chisum’s
motion and arguments to petitioner, are for convenience only.
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