S. Byrne Doyle and Barbara S. Doyle - Page 22

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          agreement in this case qualifies as a "writing" under section               
          6229(b)(1)(B).14                                                            
               In sum, we hold that Mr. Farley as the general partner was             
          "authorized by the partnership in writing" within the meaning of            
          section 6229(b)(1)(B) to execute a consent to extend the section            
          6229(a) period of limitations and, consequently, that the 1986              
          consent executed by Mr. Farley was valid, and the 1996 notice was           
          timely.  Based on this holding, we need not and do not reach                
          respondent's other arguments based on the operation of                      
          Pennsylvania partnership law alone,15 or equitable estoppel.                
          Accordingly,                                                                
                                             Decision will be entered                 
                                        for respondent.                               








               14  Petitioners argue that because the Form 2848 granting              
          Mr. Farley power of attorney to represent the partnership was               
          never filed, Mr. Farley had no authority to sign the consent.               
          But a general partner needs no power of attorney to act on behalf           
          of the partnership.  15 Pa. Cons. Stat. Ann. secs. 8321, 8533               
          (West 1995).                                                                
               15  See Cambridge Research & Development Group v.                      
          Commissioner, 97 T.C. 287, 291 (1991) (where we expressly left              
          that question open); see also Medical & Business Facilities Ltd.            
          v. Commissioner, 60 F.3d 207, 211 (5th Cir. 1995) (holding that a           
          statute is not a sufficient written authorization), revg. T.C.              
          Memo. 1994-38.                                                              





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