Starvest U.S., Inc. - Page 17

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          because it was found to be based upon the taxpayers' conduct                
          subsequent to the filing of the petition, even though the                   
          taxpayers had not expressly approved or authorized the act of               
          filing or signing their names to the petition.  In reaching that            
          conclusion, it was noted that the taxpayers were informed and               
          knowledgeable about documents received from the Government and              
          actions taken by their accountant.                                          
               The Kraasch rationale is rooted in concepts of agency and              
          ratification.  In Kraasch, the person who signed the taxpayers'             
          names was representing their interests before the IRS in the                
          handling of their tax matters.  Even though the agent did not               
          have specific authority to file a petition on their behalf, a               
          petition was filed, the taxpayers were aware of it, and they were           
          deemed to have ratified it.                                                 
               Florida case law has long recognized that ratification of an           
          agreement occurs where a person expressly or impliedly adopts an            
          act or contract entered into on his or her behalf by another                
          without express authority.  See Deutsche Credit Corp. v.                    
          Peninger, 603 So. 2d 57 (Fla. Dist. Ct. App. 1992); Carolina                
          Georgia Carpet & Textiles, Inc. v. Pelloni, 370 So. 2d 450 (Fla.            
          Dist. Ct. App. 1979).  An agreement is deemed ratified where the            
          principal has full knowledge of all material facts and                      
          circumstances relating to the act or transaction at the time of             

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