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ratification. See Ball v. Yates, 158 Fla. 521, 29 So. 2d 729
(1946); Deutsche Credit Corp. v. Peninger, supra.
Subsequent to Mr. de Bruijn's causing the second petition to
be filed, Starvest's president, Mario Boon, filed a petition with
this Court asking for a redetermination of the taxes determined
in the 1998 notice of deficiency. Additionally, at the hearing
on the motions here, one of Starvest's directors clearly stated
that the company's directors and officers were aware of and
approved of Mr. de Bruijn's causing the petitions to be filed.
Further, this director testified that the company wished to
challenge respondent's determinations in these matters.
The filing of the petition by Mr. Boon and the testimony of
Starvest's director clearly indicate and satisfy the Court that
Starvest desired to challenge respondent's determinations for the
years at issue and approved of the actions of Mr. de Bruijn in
causing the petitions to be filed. Therefore, as in Kraasch v.
Commissioner, supra, and Mishawaka Properties Co. v.
Commissioner, supra, the Court holds that a ratification was
implied based upon the officers' and directors' conduct
subsequent to the filing of the petitions, even if such officers
and directors may not have expressly approved or authorized the
act of filing the petitions.
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