- 14 - 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 andPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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