Harris Levin and Gayle Levin - Page 6

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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 an unpublished order; Toscano v. Commissioner,            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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