Union Texas International Corporation, f.k.a. Union Texas Petroleum Corporation - Page 12

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          items of correspondence were sent and received during the audit              
          process in the name of Union Texas Petroleum Corporation, without            
          any mention of a change in corporate structure.  Respondent                  
          further argues that Energy was aware of respondent's concern with            
          the accuracy of the name and signature on the Forms 872.  In                 
          fact, once respondent learned that Properties had changed its                
          name to New Petroleum, respondent immediately sought new Forms               
          872, reflecting the new name.  Moreover, respondent notes that               
          during the examination of the taxable periods of 1983 and 1984,              
          Union Texas Petroleum's Chief Executive Officer gave respondent a            
          letter certifying Lobliner's authority to execute consents for               
          those years.  Respondent contends that Energy's failure to inform            
          respondent that Lobliner, and subsequently Markowitz, no longer              
          had authority to act on behalf of New Petroleum was clearly                  
          disingenuous.                                                                
               We agree with respondent.  We are not persuaded by                      
          petitioner's attempt to obfuscate this issue with the testimony              
          of Joseph Wayne Cliett (Cliett), who was the supervisor of tax               
          audits for Old Petroleum, New Petroleum, Energy, and the other               
          affiliated corporations at the time of trial and during the                  
          taxable years in issue.  Cliett, as tax supervisor of the Union              
          Texas companies, knew of the tax returns being filed by each of              
          the different Union Texas companies.  Moreover, he was                       
          responsible for obtaining the appropriate signatures on the Forms            
          872.  Cliett testified that upon receiving the first of the last             




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