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Arcadia Plastics, Inc., a domestic corporation subject to corporate income tax, is under BIR audit for 2022–2024. The BIR issues a Letter of Authority (LOA) naming Atty. Daniel Reyes as Arcadia's authorized representative for all tax years mentioned, authorizing him to file returns, respond to inquiries, and receive notices on Arcadia's behalf. The LOA is signed by Arcadia's Chief Financial Officer and attested by the Corporate Secretary, but Arcadia's by-laws require the consent of the Board of Directors for any delegation of representation in tax matters; no board resolution authorizing this delegation exists. The BIR proceeds with the audit, issues a deficiency assessment addressed to Arcadia Plastics, Inc. and to Atty. Reyes as recipient. Arcadia contends the LOA is invalid; the BIR maintains the LOA is valid. (a) Identify the controlling doctrine governing representation before the BIR and the effect of a valid Power of Attorney on the BIR's jurisdiction to audit, assess, and collect. (b) Distinguish actual authority, apparent authority, and agency by estoppel as they relate to representation before the BIR, and indicate which applies to the facts. (c) Apply to the facts: if the LOA is invalid for lack of proper corporate authorization, what remedies, if any, does Arcadia have, and how is the deficiency assessment affected? Is the BIR's action binding on Arcadia and third parties?