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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.
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