Joanne Soon Kim - Page 7

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            taxpayer's name it is nevertheless valid, if under the facts in                               
            the record, that agent had authority to act on behalf of the                                  
            taxpayer with respect to the matter covered by the document.                                  
            Kraasch v. Commissioner, supra at 627.  Based on the power of                                 
            attorney signed by petitioner, Mr. Zuehls had express authority                               
            to act on behalf of petitioner in consenting to extend the period                             
            of limitations for assessment of tax.  Also, based on this                                    
            record, it appears that petitioner had given Mr. Kim authority to                             
            act on her behalf with respect to her income tax matters for                                  
            1989.  She testified with respect to receipt of documents from                                
            the IRS addressed to her only, which she sent unopened to Mr.                                 
            Kim.  Mr. Kim was not called as a witness in this case.                                       
            Petitioner did not question the validity of the Form 872 until                                
            after the mailing of the notice of deficiency.  Her activities as                             
            a whole indicate that she considered that Mr. Kim had the                                     
            authority to consent on her behalf to an extension of the period                              
            of limitations for 1989.  Petitioner's intent was that her                                    
            husband handle their 1989 income tax matters including, if                                    
            needed, extending the period of limitations on assessment of tax                              
            against her, as well as himself.  See Estate of Campbell v.                                   
            Commissioner, 56 T.C. 1, 13 (1971).                                                           
                  Petitioner has not shown who signed her name to the Form                                
            872.  If it was Mr. Zuehls, he had authority under the power of                               
            attorney she signed to do so.  If it was Mr. Kim, he had implied                              
            authority to do so.  Certainly, by failure to question the                                    
            validity of the Form 872 for an extended period of time,                                      



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