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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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