MEMORANDUM OPINION
GERBER, Judge:
Respondent, in a notice of deficiency addressed to Ranghild Elton (Ms. Elton), determined a deficiency in her 1996 Federal income tax and an accuracy-related penalty. Pursuant to a trust agreement executed by Ranghild Elton, Kenneth Siebert was empowered to, among other things, "file petitions to the U.S. Tax Court". After the petition was filed, the trust was voided ab initio. Ms. Elton seeks to replace Kenneth Siebert...
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