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broad since it is clear that the execution of consent does not
fall within the scope of the provisions which limited such
authority in respect of a major partnership action. See supra p.
3. Thus, we do not have the situation which existed in Medical &
Business Facilities Ltd. v. Commissioner, 60 F.3d 207 (5th Cir.
1995), revg. T.C. Memo. 1994-38, where there was no broad grant
of authority to any individual general partner in the partnership
agreement and the agreement contained considerably broader
restrictions on the actions of an individual general partner than
exist herein.
In Cambridge Research & Development Group v. Commissioner,
97 T.C. 287, 289, 300 (1991), we held that the authority granted
in a partnership agreement to a general partner to "take any
action or do anything in furtherance of the Partnership business"
(quoting partnership agreement) was enough to satisfy the
requirements of section 6229(b)(1)(B) to authorize that general
partner in writing to execute a consent to extend the section
6229(a) period of limitations, as long as extending such a period
of assessment was within the scope of partnership business under
State law. See Bugaboo Timber Co. v. Commissioner, 101 T.C. at
484. We also held that a high level of specificity for
authorizations made before the effective date of the regulations
is not required--a broad grant of authority will suffice for the
purposes of the statute. Cambridge Research & Development Group
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