- 18 - fiduciary of petitioner and a detailed analysis of why such purported fiduciary has the capacity to litigate in the Court on behalf of petitioner. On December 19, 2001, respondent filed separate written responses to the December 3, 2001 Show Cause Orders in the cases at docket Nos. 10764-00 and 10767-00 in which respondent con- tended, inter alia, that Richards Management Trust and Richards Charitable Trust, respectively, 11. * * * failed to establish that a trustee, if authorized, acted on its behalf when the purported petition was filed with the Court on October 16, 2000. 12. * * * failed to file a proper petition with this Court in that the petition was not brought by and with the full descriptive name of the fiduciary enti- tled to institute a case on its behalf. Respondent further argued in those separate responses to the December 3, 2001 Show Cause Orders in the cases at docket Nos. 10764-00 and 10767-00 that Since the petition in this case was not brought by a 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, respectively, filed 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.Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011