Roland Gyula Szasz - Page 14

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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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