Lloyd T. Asbury, Attorney at Law, P.A. - Page 15

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             Respondent cites no authority in support of this                         
             interpretation of Rule 24(b).                                            
                  The Explanatory Note that accompanied the promulgation              
             of Rule 24(b) states as follows:                                         
                       Par. (b) is concerned with pro se                              
                  appearances, and is the counterpart of present                      
                  T.C. Rule 3.  However, Par. (b) states a rule,                      
                  not expressed in T.C. Rule 3, that a party is                       
                  deemed to appear for himself in the absence of                      
                  appearance by counsel.  In such event, the Clerk                    
                  can make service of papers by directing them by                     
                  mail to the party, foreclosing any claim of                         
                  failure to serve counsel.  Par. (b) goes beyond                     
                  T.C. Rule 3 in specifying the information                           
                  required of the pro se party, and expands the                       
                  provision on the persons who may act in a                           
                  representative capacity for a pro se party.  [60                    
                  T.C. 1078.]                                                         
             Thus, among other things, Rule 24(b) was intended to expand              
             the scope of former Rule 3, its counterpart, regarding the               
             persons who could act in a representative capacity for a                 
             pro se party.  Former Rule 3 provided in part as follows:                
             “A taxpayer corporation may be represented by a bona fide                
             officer of the corporation upon permission granted, in its               
             discretion, by the Court or the Division sitting.”  Thus,                
             under former Rule 3, an officer of a corporation could                   
             represent the corporation in this Court, but the officer                 
             was required to obtain the permission of the Court to do                 
             so.  Rule 24(b) expanded the scope of former Rule 3 by                   
             permitting a corporation to be represented in this Court                 
             “by an authorized officer of the corporation”.                           





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