Lloyd T. Asbury, Attorney at Law, P.A. - Page 6

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             corporation in this Court.  According to respondent:                     
             “Mr. Asbury cannot act in a representative capacity for                  
             petitioner” because Florida law “does not grant authority                
             to a former officer to represent a dissolved entity, with                
             exceptions not applicable here.”                                         
                  Petitioner bears the burden of establishing                         
             affirmatively all facts giving rise to our jurisdiction.                 
             See Patz Trust v. Commissioner, 69 T.C. 497, 503 (1977);                 
             Fehrs v. Commissioner, 65 T.C. 346, 348 (1975); Wheeler’s                
             Peachtree Pharmacy, Inc. v. Commissioner, 35 T.C. 177, 180               
             (1960).  Petitioner must establish that:  (1) Respondent                 
             issued to petitioner a valid notice of deficiency, and (2)               
             petitioner, or someone authorized to act on petitioner’s                 
             behalf, filed a timely petition with the Court.  See Rule                
             13(a), (c); Monge v. Commissioner, 93 T.C. 22, 27 (1989);                
             Fehrs v. Commissioner, supra at 348.  In order to meet this              
             burden, petitioner must establish that Mr. Asbury has                    
             authority to act on petitioner’s behalf.  See Natl. Comm.                
             to Secure Justice v. Commissioner, 27 T.C. 837, 839-840                  
             (1957); Coca-Cola Bottling Co. v. Commissioner, 22 B.T.A.                
             686, 700 (1931); cf. Scenic Wonders Gallery, LLC v.                      
             Commissioner, T.C. Memo. 2000-64.  If the petition is not                
             filed by petitioner, or by someone lawfully authorized to                
             act on petitioner’s behalf, then we are without                          






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