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small number of employees so that no one else had access to an
actual signature to trace or simulate; the fact that the Form
2553, when returned to the JPS address for additional
information, was promptly resubmitted with extensive details
concerning JPS; and the fact that petitioner was in charge of
financial operations. Petitioner puts considerable weight on his
affidavit, in which he declares that he did not authorize anyone
to sign his name. We need not accept a taxpayer's self-serving
testimony as gospel. Tokarski v. Commissioner, 87 T.C. 74, 77
(1986); Three G Trading Corp. v. Commissioner, T.C. Memo. 1988-
131 (declining to accept self-serving testimony in a summary
judgment case). On the other hand, we may not merely rely on
factual assertions in respondent's brief, which are not
sufficient to defeat petitioner's motion. Smith v. Commissioner,
T.C. Memo. 1983-706. In this case, however, the scenario that
respondent suggests on brief is sufficiently plausible, given the
facts in the record, for us to find that petitioner has not made
a prima facie showing of the absence of a factual issue. The
Form 2553 itself reflects preparation by someone with
considerable information concerning JPS's affairs. Therefore,
respondent need not come forth with affidavits or other
documentary evidence to refute petitioner's position. Abramo v.
Commissioner, 78 T.C. 154, 163-164 (1982); Rosberg v.
Commissioner, T.C. Memo. 1988-267. We find that there is a
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