- 29 - 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.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011