A partnership can consent to allow the IRS to extend the statute of limitations by signing Form 872-P. Normally, the Form would have to be signed by a designated tax matters partner. However, in this case, the signer was no the designated tax matters partner. The court held that the signature was effective to allow the statute of limitations to be extended because the signer had apparent authority and the IRS was reasonable in believing that the signer had the authority to act on the partnership's behalf. The signed had also signed the partnership's tax return and was a managing member. Summit Vineyard Holdings, LLC, et al. v. Comr., T.C. Memo. 2015-140.