Northstate Tax Consultants - Page 4

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          proving that this Court has jurisdiction.  Harold Patz Trust v.             
          Commissioner, 69 T.C. 497, 503 (1977); Fehrs v. Commissioner, 65            
          T.C. 346, 348 (1975); Main-Hammond Land Trust v. Commissioner, 17           
          T.C. 942, 957 (1951), affd. 200 F.2d 308 (6th Cir. 1952).                   
               Petitioner failed to comply with our order requiring a                 
          response to respondent’s motion to dismiss for lack of                      
          jurisdiction.  Petitioner has failed to present other evidence              
          showing that this Court has jurisdiction.  In the absence of any            
          evidence to support our jurisdiction, we hold that Mr. Kent does            
          not have the capacity under Rule 60(c) to litigate in this Court            
          on behalf of NTCT.  See Harold Patz Trust v. Commissioner, supra.           

                                             An appropriate order will                
                                        be entered granting respondent’s              
                                        motion to dismiss for lack of                 
                                        jurisdiction.                                 





















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