Greg William Gouveia, a.k.a. Greg W. Gouveia, a.k.a. Greg Gouveia & Carol Ann Gorveia, a.k.a. Carol Gouveia, et al. - Page 29

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          continuing basis; and established a pattern of forwarding all tax           
          communications from the Commissioner to the agent.                          
               Other than petitioners’ having filed Form 2848, none of the            
          facts or circumstances mentioned in the cases discussed above are           
          present herein.  In the absence of any credible evidence to                 
          establish that Mr. Izen and the trustees had a relationship from            
          which we could infer that a sufficient grant of authority                   
          occurred or that they ever communicated with each other regarding           
          the filing of petitions on behalf of the trusts, we find that               
          petitioners have failed to prove that the trustees authorized Mr.           
          Izen to petition this Court on behalf of the Pago and McKenzie              
          Trusts.  Accordingly, we grant respondent’s motion to dismiss the           
          petitions filed by the Pago and McKenzie Trusts for lack of                 
          jurisdiction, on the ground that no proper persons have                     
          petitioned the Court.  As a result of our ruling, we do not                 
          consider or decide any issue raised in the petitions filed in the           
          names of the Pago and McKenzie Trusts.                                      


















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