WFO Corporation, et al. - Page 24

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          settled issues that their counsel signed.  Respondent’s Motion              
          for Entry of Decisions will therefore be granted.                           
          II. Representation of WFO                                                   
               Rule 24(b) provides that a corporation may be represented in           
          Tax Court proceedings by an authorized officer.  Under Rule                 
          63(c), we have the authority to allow the substitution of a                 
          corporate party’s representative.  Rule 60(c) provides that the             
          capacity of a fiduciary or other representative to litigate                 
          before the Tax Court is determined “in accordance with the law of           
          the jurisdiction from which such person’s authority is derived.”            
               Mrs. Wolfe signed WFO’s petition and served as its sole                
          authorized representative under Rule 24(b) until Mr. McCarthy               
          entered his appearance on behalf of WFO on January 13, 2003.                
          When we granted Mr. McCarthy’s motion to withdraw as counsel on             
          April 18, 2003, a dispute arose regarding the person authorized             
          to represent WFO in this proceeding.  In submissions made on                
          April 20 and 22, 2003 (which were not filed), and on June 4,                
          2003, Mr. Mansour asserted that he was a corporate officer of WFO           
          and purported to sign those submissions on behalf of WFO.  In a             
          letter received June 4, 2003, Mrs. Wolfe disputed Mr. Mansour’s             
          status as a corporate officer and his right to represent WFO in             
          this proceeding.  We treat Mr. Mansour’s June 4 submission as a             
          motion to be substituted as WFO’s representative in this                    
          proceeding pursuant to Rule 63(c).                                          






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