Sharon E. Backstrom, Harold J. and Zelma G. Barbret, Virginia Boland, John A. and Theresa A. Cislaghi, Estate of Roger W. Dornbrock, Gary E. and Beverly G. Engel, Hermann K. and Helen W. Enzmann, - Page 23

                                       - 23 -                                         

          notice of deficiency.11  Indeed, Mrs. Dornbrock failed to show              
          how Mr. Young could have obtained the correct amounts of                    
          deficiencies and additions to tax, to include in the joint                  
          petition, unless her husband had indeed forwarded their notice of           
          deficiency to Mr. Young through Mr. Pasternak.  On the entire               
          record, this Court is convinced that Mr. Young was given the                
          authority, by Mr. Dornbrock, to represent both Mr. and Mrs.                 
          Dornbrock in the filing of the joint petition in this case on               
          their behalf.                                                               
               The joint petition was timely filed and Mr. Young thereby              
          became counsel of record for Mr. and Mrs. Dornbrock in this case.           
          It is notable that the appearance of an attorney on behalf of an            
          individual creates a presumption that the attorney has the                  
          authority to represent that individual.  Osborn v. Bank of United           
          States, 22 U.S. (9 Wheat.) 738, 830 (1824); Gray v. Commissioner,           
          73 T.C. 639, 646 (1980).  No motion to remove or cause the                  
          withdrawal of Mr. Young as counsel for Mr. Dornbrock, Mrs.                  
          Dornbrock, or Mr. Dornbrock's estate was filed until after Mrs.             
          Dornbrock filed the subject motion seeking to vacate or revise              
          the decision, nor, for that matter, have any of the other                   
          petitioners in this case filed any motion to remove Mr. Young or            
          to vacate the decision entered against them.  Thus, it appears at           

          11                                                                          
               In fact, Mr. Young testified, and the record reflects, that            
          he represented most, but not all, of the Pop Phonomasters                   
          investors.                                                                  




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