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authorized to handle the affairs of and protect the interests of
Starvest with respect to its tax matters for the years at issue,
regardless of the title under which he acted. Causing the
petitions to be filed in Starvest's name was among the duties
that he performed on the corporation's behalf. Based upon the
foregoing facts and the principles of agency, therefore, the
Court holds that Jacques de Bruijn was authorized to cause the
petitions in these cases to be filed on behalf of Starvest.
Even if the Court were to conclude that Starvest did not
authorize Mr. de Bruijn to cause the petitions to be filed on its
behalf, there is ample evidence that Starvest ratified the filing
of the petitions. In this regard, this Court has held that a
taxpayer can ratify a previously filed petition, even in the
absence of express approval, through action or inaction
implicitly approving the filing of the petition. See Mishawaka
Properties Co. v. Commissioner, 100 T.C. 353 (1993); Kraasch v.
Commissioner, supra.
In Kraasch v. Commissioner, supra at 627, 628, this Court
found that the accountant, in filing the petition, "acted as the
authorized agent of * * * [the taxpayers]" and that "even if this
were a situation where * * * [the accountant] acted upon * * *
[the taxpayers'] behalf without authority, * * * [the taxpayers]
are still bound * * * because they subsequently ratified * * *
[the accountant's] actions." The ratification was implied
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