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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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