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party with proper capacity as required by the Tax Court
Rules of Practice and Procedure, the Court lacks juris-
diction * * *.
On December 20, 2001, Richards Management Trust and Richards
Charitable Trust filed separate written responses to the December
3, 2001 Show Cause Orders in the cases at docket Nos. 10764-00
and 10767-00 (Richards Management Trust’s response to the Decem-
ber 3, 2001 Show Cause Order and Richards Charitable Trust’s
response to the December 3, 2001 Show Cause Order, respectively),
each of which was signed by Terrence A. Bentivegna (Mr.
Bentivegna) who identified himself in each such response as
“Trustee”. Each such response asserted that “Petitioner does not
believe that this Court has jurisdiction.” In support of that
position, Richards Management Trust’s response to the December 3,
2001 Show Cause Order and Richards Charitable Trust’s response to
the December 3, 2001 Show Cause Order set forth statements and
contentions that the Court finds to be frivolous and/or ground-
less.6
6Each such response to the December 3, 2001 Show Cause Order
stated in pertinent part:
1. Petitioner petitioned this Court after having
received false and misleading information from the
respondent and attorneys David Wise and his asso-
ciate Carol Jackson. The respondent has failed to
properly assess any taxes in accordance with their
required administrative procedures, and yet ad-
vised the petitioner that the only method of dis-
agreeing with the purported tax liability was to
petition this Court.
(continued...)
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