Lloyd T. Asbury, Attorney at Law, P.A. - Page 7

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             jurisdiction to consider it.  See, e.g., Fehrs v.                        
             Commissioner, supra at 348; Photo Art Mktg. Trust v.                     
             Commissioner, T.C. Memo. 2000-57.                                        
                  Rule 60 provides, in pertinent part, as follows:                    
                       (a) Petitioner:  (1) Deficiency or Liability                   
                  Actions:  A case shall be brought by and in the                     
                  name of the person against whom the Commissioner                    
                  determined the deficiency (in the case of a                         
                  notice of deficiency) * * * or by and with the                      
                  full descriptive name of the fiduciary entitled                     
                  to institute a case on behalf of such person.                       
                  See Rule 23(a)(1).  A case timely brought shall                     
                  not be dismissed on the ground that it is not                       
                  properly brought on behalf of a party until a                       
                  reasonable time has been allowed after objection                    
                  for ratification by such party of the bringing                      
                  of the case; and such ratification shall have the                   
                  same effect as if the case had been properly                        
                  brought by such party.  * * *                                       
                        *     *     *     *     *     *     *                         
                       (c) Capacity:  * * *  The capacity of a                        
                  corporation to engage in such litigation shall be                   
                  determined by the law under which it was                            
                  organized.  The capacity of a fiduciary or other                    
                  representative to litigate in the Court shall be                    
                  determined in accordance with the law of the                        
                  jurisdiction from which such person’s authority                     
                  is derived.                                                         
             Rule 24(b) provides as follows:                                          
                       (b) Personal Representation Without Counsel:                   
                  In the absence of appearance by counsel, a                          
                  party will be deemed to appear on the party’s                       
                  own behalf.  * * *  A corporation * * * may be                      
                  represented by an authorized officer of the                         
                  corporation * * *.  * * * Any such person shall                     
                  state, in the initial pleading or other paper                       
                  filed by or for the party, such person’s name,                      
                  address, and telephone number, and thereafter                       
                  shall promptly notify the Clerk in writing, in                      






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