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provide evidence establishing who has the authority to act on its
behalf in each such proceeding. See Natl. Comm. to Secure
Justice in the Rosenberg Case v. Commissioner, supra at 839-840;
Coca-Cola Bottling Co. v. Commissioner, 22 B.T.A. 686, 700
(1931).
On the instant record, we find that Richards Management
Trust in the case at docket No. 10764-00 and Richards Charitable
Trust in the case at docket No. 10767-00 have failed to establish
who has the authority to act on their behalf in those respective
proceedings. We further find on that record that neither of the
cases at docket Nos. 10764-00 and 10767-00 was brought by and
with the full descriptive name of the fiduciary entitled to
institute each such case on behalf of Richards Management Trust
or Richards Charitable Trust, as the case may be, as required by
Rule 60(a)(1). On the record before us, we conclude that we do
not have jurisdiction over the cases at docket Nos. 10764-00 and
10767-00. Accordingly, we shall dismiss those cases for lack of
jurisdiction.12
Mr. Richards
Neither Mr. Richards nor any authorized representative of
Mr. Richards appeared at the Court’s Cleveland trial session on
12Because we shall dismiss the cases at docket Nos. 10764-00
and 10767-00 for lack of jurisdiction, we shall deny respondent’s
motion in the case at docket No. 10764-00 and respondent’s motion
in the case at docket No. 10767-00.
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