Francisco E. Campos, Jr. and Lualhati N. Campos - Page 3

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          to act as guardian ad litem in this matter.  Respondent filed a             
          Notice of No Objection to the motion.                                       
               Pursuant to notice, this matter was set for hearing at the             
          Court’s motions session in Washington, D.C.  Counsel for                    
          respondent appeared at the hearing and was heard.  Petitioners              
          filed with the Court a written statement under Rule 50(c) in lieu           
          of attending the hearing.                                                   
               During the hearing of this matter, respondent averred that             
          the Court has the authority to appoint Mrs. Campos as guardian ad           
          litem for Mr. Campos under the same general procedure that the              
          Court employed in Estate of Galloway v. Commissioner, 103 T.C.              
          700 (1994).  In Estate of Galloway, the Court relied upon                   
          California law to appoint a special administrator to represent              
          the interests of a deceased taxpayer/petitioner.  Respondent also           
          acknowledged that the Court could recognize Mrs. Campos as Mr.              
          Campos’s “next friend” under Rule 60(d).                                    
               It is well settled that the Court’s jurisdiction to                    
          redetermine a deficiency depends upon a valid notice of                     
          deficiency and a timely filed petition for redetermination.  Rule           
          13(a), (c); Monge v. Commissioner, 93 T.C. 22, 27 (1989); Normac,           
          Inc. v. Commissioner, 90 T.C. 142, 147 (1988).  Rule 34 sets                
          forth the basic requirements for filing a valid petition with the           
          Court.  Rule 34(a)(1) provides in pertinent part:                           

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