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deficiency for 1979 and 1982, each of which was dated September
6, 1989. As to petitioner, therefore, the notices of deficiency
for taxable years 1979 and 1982 were timely issued, as extended
by statute and agreement, and the assessments for 1979 and 1982
are not barred by the statute of limitations.
With respect to petitioner Brenda Becker, however, the
notice of deficiency for 1979 was not timely issued. The Form
872-A executed by respondent and petitioner for 1982 was not
signed by Brenda Becker, nor does her name appear in the
document. Brenda Becker did not personally execute a Form 872,
Consent to Extend the Time to Assess Tax, for 1979 or 1982.
Respondent has not shown that when petitioner signed the Form
872-A for 1982, he was acting as an authorized agent for, or
otherwise on behalf of, Brenda Becker. To the contrary,
petitioner's testimony indicates that Brenda Becker had no
knowledge about his investments in the Partnership transactions,
his application for and receipt of a refund for taxable year
1979, or his extension of the period of limitations for 1982. We
hold that the Form 872-A executed by petitioner and respondent
did not extend the period of limitations with respect to Brenda
Becker. Consequently, the notice of deficiency for 1979 is time
barred as to Brenda Becker.9 Tallal v. Commissioner, 77 T.C.
9 Although the matter is not addressed by the parties, we note
that their Second Stipulation of Facts arguably renders the
statute of limitations issue with respect to petitioner Brenda
(continued...)
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