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not signed the Form 872, citing Malone & Hyde, Inc. v.
Commissioner, T.C. Memo. 1992-661, for support. But petitioner’s
reliance on the latter case is nullified by the fact that Chang,
who did sign the Form 872, was president of both corporations
and, as we have demonstrated, was well aware that only SFWP's
taxable year could have been intended.
SFWP further argues that the Form 872 is invalid because
Chang did not have the authority to sign the Form 872 on behalf
of SFWP. Authority to act on behalf of a corporation in tax
matters is determined by State law. Sanderling, Inc. v.
Commissioner 66 T.C. 743, 750 (1976), affd. in part and revd. in
part 571 F.2d 179 (3d Cir. 1978). Since SFWP was a California
corporation, we determine the scope of an agent's authority under
California law.
Under California law, a corporation that has dissolved may
still carry out acts necessary to wind up its affairs, including
those relating to taxes. See Cal. Corp. Code sec. 2010(a) (West
1990); Callan v. Commissioner, 476 F.2d 509 (9th Cir. 1973),
affg. per curiam 54 T.C. 1514 (1970). California Corporations
Code section 2001 (West 1990) provides in pertinent part:
The powers and duties of the directors * * * and officers
after commencement of a dissolution proceeding include, but
are not limited to, the following acts in the name and on
behalf of the corporation:
* * * * * * *
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