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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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