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testimony that the signature was not actually written by
petitioner. However, respondent does contend, based on her
agent's testimony, that this fact was not apparent to any
representative of the IRS who had occasion to review the Form
872. Petitioner contends that respondent should have known by
examination of the Form 872 that the signature was not her
signature, and, therefore, the form was invalid on its face.
Agent Novella testified that both she and her supervisor examined
the Form 872 and would have noted any large discrepancies between
the signature on the form and the signature on petitioner's tax
return, but noticed none. We find this to be credible testimony,
particularly after a review of the signatures on the two
documents. Therefore, the burden is on petitioner to show that
the Form 872 is invalid.
Based on the record in this case, we hold that petitioner
has not met her burden of proving that the Form 872 is invalid.
Petitioner has made no showing of who might have signed her name
to the Form 872. She did not call Mr. Zuehls as a witness but
claims she did not consent to his signing her name to the Form
872. Clearly she had given Mr. Zuehls the power to consent for
her to an extension of the period of limitations. The extent of
an agent's authority is a factual question to be decided on the
basis of facts and circumstances shown in the record. Adams v.
Commissioner, 85 T.C. 359, 369-372 (1985); Kraasch v.
Commissioner, 70 T.C. 623, 627-629 (1978). We have held that
where a document is signed by the taxpayer's agent in the
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