S. Byrne Doyle and Barbara S. Doyle - Page 14

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          discussion in Amesbury Apartments, Ltd. v. Commissioner, 95 T.C.            
          227, 240-241 (1990).                                                        
               A consent is valid on its face if it includes the name of              
          the taxpayer, the signature of the taxpayer or a person                     
          authorized to sign on the taxpayer's behalf, the taxable year as            
          to which the period is to be extended, and was signed on a date             
          prior to the expiration of the limitations period.  Lefebvre v.             
          Commissioner, T.C. Memo. 1984-202, affd. 758 F.2d 1340 (9th Cir.            
          1985).  A consent signed by a person who has represented the                
          taxpayer before respondent, as Mr. Farley did on several                    
          occasions prior to the signing of the 1986 consent, whether                 
          signed on the line for "authorized representative", or in this              
          case for "tax matters partner", is valid on its face.  Bugaboo              
          Timber Co. v. Commissioner, 101 T.C. 474 (1993); Cambridge                  
          Research & Development Group v. Commissioner, 97 T.C. 287 (1991);           
          Amesbury Apartments, Ltd. v. Commissioner, supra.  Under the                
          circumstances herein, we reject petitioners' contention that                
          respondent had a duty to look beyond the consent to ascertain               
          whether Mr. Farley was indeed the TMP or otherwise authorized to            
          act for the partnership.                                                    
               Petitioners also argue that the 1986 consent was not valid             
          on its face because Mr. Farley did not attach a copy of the                 
          written authorization from the partnership to the consent form.             
          In this connection, we note that Mr. Farley signed as TMP and               






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