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years ordinarily would have expired on April 15, 2002, and April
15, 2003, respectively. Respondent contends, however, that
petitioner duly executed a consent, which is valid on its face,
extending the period of limitations to June 30, 2003, and that
respondent issued the notice of deficiency before such date.
When a consent appears regular on its face and in accordance
with law, we generally presume that the parties who signed the
consent acted within the scope of their authority. Concrete Engg
Co. v. Commissioner, 19 B.T.A. 212, 221 (1930), affd. 58 F.2d 566
(8th Cir. 1932); Ryan v. Commissioner, T.C. Memo. 1991-49. The
last consent properly identifies petitioner as the taxpayer and
bears the signature of petitioner’s representative, Mr. Penn, who
acted pursuant to a valid Form 2848. Furthermore, respondent’s
authorized representative executed the last consent before the
expiration of the period of limitations. Therefore, respondent
has introduced a consent form that appears to be valid, and
petitioner must prove that the last consent is invalid. See Ryan
v. Commissioner, supra; Lefebvre v. Commissioner, T.C. Memo.
1984-202, affd. per curiam 758 F.2d 1340 (9th Cir. 1985).
Petitioner contends that the last consent is invalid because
Mr. Penn did not have the requisite authority to execute an
extension on petitioner’s behalf. In this regard, petitioner
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