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jurisdiction over the cases at docket Nos. 10764-00 and 10767-00.
Rule 60 provides in pertinent part:
(a) Petitioner: (1) Deficiency or Liability
Actions: A case shall be brought by and in the name of
the person against whom the Commissioner determined the
deficiency (in the case of a notice of deficiency)
* * * or by and with the full descriptive name of the
fiduciary entitled to institute a case on behalf of
such person. See Rule 23(a)(1). A case timely brought
shall not be dismissed on the ground that it is not
properly brought on behalf of a party until a reason-
able time has been allowed after objection for ratifi-
cation by such party of the bringing of the case; and
such ratification shall have the same effect as if the
case had been properly brought by such party. * * *
* * * * * * *
(c) Capacity: * * * The capacity of a fiduciary
or other representative to litigate in the Court shall
be determined in accordance with the law of the juris-
diction from which such person’s authority is derived.
The record does not establish where Richards Management
Trust and Richards Charitable Trust were organized. The respec-
tive petitions in the cases at docket Nos. 10764-00 and 10767-00
listed an address for Richards Management Trust and Richards
Charitable Trust in Canton, Ohio,10 which is also the service
address used by the Court in those cases. Assuming arguendo that
Richards Management Trust and Richards Charitable Trust were
trusts organized under the laws of the State of Ohio, the admin-
istration of each of which is subject to the laws of that State,
10The Ohio address listed in the respective petitions in the
cases at docket Nos. 10764-00 and 10767-00 is the same address
listed by Mr. Richards in the respective cases at docket Nos.
10765-00 and 10766-00.
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