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generally, Billingsley v. Commissioner, 868 F.2d 1081, 1084 (9th
Cir. 1989), revg. an unpublished order; Toscano v. Commissioner,
441 F.2d 930, 934 (9th Cir. 1971), vacating and remanding 52 T.C.
295 (1969); Brannon's of Shawnee, Inc. v. Commissioner, 69 T.C.
999, 1002 (1978).
Ms. Levin contends and testified that she did not authorize
Mr. Levin to execute the power of attorney in favor of Anson, did
not authorize Anson to extend the period of limitations, did not
authorize Gelfand or anyone to file a petition on her behalf, and
did not agree to the settlement of this case or authorize anyone
to do so on her behalf. She recounts a series of grievances
against Mr. Levin over most of their 30-year marriage.
Mr. Levin testified pursuant to subpoena served by
respondent and denied many of Ms. Levin's accusations. He
testified that he showed her or told her about all material
correspondence involving the Schulman matter and that she
authorized him to sign her name to the power of attorney and
stipulation. Ms. Levin attacks Mr. Levin's credibility. She
disputes his claimed lack of recollection of 1975 divorce
proceedings. She argues that his apparent simulation of her
signature refutes his claim of authority, asserting that, if he
were truly authorized, he would not have found it necessary to
make the signature look like hers.
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