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expired on April 15, 1984, 3 years after petitioner filed his
1980 return, unless the period was extended by agreement. There
is also no disagreement that respondent issued the statutory
notice on May 3, 1994, more than 10 years after April 15, 1984.
Petitioner thus has made a prima facie showing that the notice is
untimely. That demonstration placed upon respondent the burden
of producing evidence that the bar effected by expiration of the
period of limitations is inapplicable. Respondent has made such
a showing by providing a facially valid Form 872-A, indicating
that both petitioner and Wynne agreed to waive the period of
limitations applicable to their 1980 taxable year. Production of
the Form 872-A placed upon petitioner the burden of showing that
the agreement exemplified in the Form 872-A is inapplicable.
Petitioner has undertaken to show that the agreement to
extend the period of limitations is invalid because he never
signed, authorized, or ratified the Form 872-A in issue. His
signature on that form, he asserts, was forged.
Section 6064 provides that “The fact that an individual’s
name is signed to a * * * document shall be prima facie evidence
for all purposes that the * * * document was actually signed by
him.”
To overcome the presumption that he signed his name to the
consent, petitioner has offered the expert report of Diane Marsh,
a forensic document examiner. Ms. Marsh has been certified by
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