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Techs. Trust v. Commissioner, T.C. Memo. 1994-366, affd. without
published opinion sub nom. Anderson v. Commissioner, 106 F.3d 406
(9th Cir. 1997); Ripley v. Commissioner, T.C. Memo. 1987-114. In
Trenerry v. Commissioner, T.C. Memo. 1994-500, the taxpayer
appeared pro se in a case in which the Court held that a trust
was to be disregarded for tax purposes. The Court stated:
Petitioner relies on two legal opinion letters of
Joe Alfred Izen, Jr. (hereinafter sometimes referred to
as Izen) which she had obtained from Century. Izen’s
opinion letters, addressed to Century, dated
September 25, 1986, discuss the legal status and tax
status of contractual trust companies. Although Izen’s
opinion letters are dated almost 4 years after our
published opinion in Zmuda [v. Commissioner, 79 T.C.
714 (1982), affd. 731 F.2d 1417 (9th Cir. 1984)] (and
more than 2 years after the published Court of Appeals
affirmance), neither of his opinion letters refers to
Zmuda. We note the August 15, 1984, changes to the
Trenerry Trust, in which petitioner (as grantor) warned
herself (as trustee) “to beware of attorneys and to
avoid them whenever at all possible.” Perhaps this was
one instance in which petitioner should have followed
her own advice. The Izen opinion letters do not help
petitioner on the evidence in the instant case. [Fn.
ref. omitted.]
See also Para Techs. Trust v. Commissioner, T.C. Memo. 1992-575.
Cases in which Izen was counsel also reflect chronic failure
to comply with discovery orders or Court Rules. In Oelze v.
Commissioner, 723 F.2d 1162 (5th Cir. 1983), the Court of Appeals
affirmed dismissal of petitions where, in response to the Tax
Court’s repeated orders to comply with the Commissioner’s
discovery requests and admonishments that failure to comply would
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