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The record establishes that Mrs. Dornbrock habitually turned
over the responsibility of dealing with the couple's business and
financial matters, including their Federal income tax matters, to
her husband. Mrs. Dornbrock trusted her husband completely and
signed their joint Federal income tax returns without even
reviewing them. Furthermore, Mrs. Dornbrock never opened any
mail that appeared to be financially or tax related, even though
it may have been addressed jointly to her and her husband. Mrs.
Dornbrock was aware of correspondence received from the IRS;
however, she allowed Mr. Dornbrock to deal with such matters
without question. This conduct impliedly authorized Mr.
Dornbrock to represent Mrs. Dornbrock with respect to their
Federal income tax matters. Mr. Dornbrock acted within the scope
of this authority when he retained Mr. Young, by and through Mr.
Pasternak, to file a petition with this Court. Mr. Young acted
pursuant to the authority granted to him by Mr. Dornbrock on Mr.
and Mrs. Dornbrock's behalf when he filed the joint petition in
this case. "Even if * * * [the taxpayer] was not aware of the
dispute with the IRS, her own admitted delegation of authority to
her husband cannot now be revoked because she is unhappy with the
outcome of her case. 'Deficiencies ex post do not detract from
authority ex ante.'" DiSanza v. Commissioner, T.C. Memo. 1993-
142, affd. without published opinion 9 F.3d 1538 (2d Cir. 1993).
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