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(2) relief is not available to such individ-
ual under subsection (b) or (c),
the Secretary may relieve such individual of such
liability.
In the instant case, the parties agree that relief is not avail-
able to petitioner under section 6015(b) or (c), thereby satisfy-
ing section 6015(f)(2). They disagree over whether petitioner is
entitled to relief under section 6015(f).
In support of her position that she is entitled to relief
under section 6015(f), petitioner relies, inter alia, on the
testimony of Mr. Simon and her own testimony. We found Mr.
Simon’s testimony to be questionable and not credible in certain
material respects. For example, Mr. Simon testified that he
signed petitioner’s name on the 1998 return. We did not believe
that testimony. We also found Mr. Simon’s testimony to be at
times confusing, confused, internally inconsistent, and/or
inconsistent with certain of the parties’ stipulations of fact
and certain exhibits attached to those stipulations (stipulated
exhibits). We shall not rely on Mr. Simon’s testimony to support
petitioner’s position in this case. We also found petitioner’s
testimony to be questionable and not credible in certain material
respects. For example, petitioner testified that she did not
sign the 1998 return. We did not believe that testimony.
Moreover, petitioner’s testimony that she did not sign the 1998
return is inconsistent with the parties’ stipulation that she did
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