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return for himself and petitioner while he was in Maryland and
petitioner was in Florida. On brief, petitioner has abandoned
her claim that she did not sign the joint return and seeks relief
from joint and several liability under section 6015(f). We must,
however, note the facts in the record that contradict
petitioner’s initial version because the diminished credibility
of petitioner goes to the merits of the application of section
6015(f). Petitioner’s initial contention that she did not sign
the joint return and that her husband filed the return in
Maryland is directly contradicted by the postmark on the return
from the town where she lived in Florida. There is no logical
reason for the return to have been in Florida other than for
petitioner to review and sign it. Petitioner has not provided
any explanation for this inconsistency. The record’s direct
contradiction of petitioner’s statements strongly diminishes her
credibility.
Further, even if petitioner did not actually sign the joint
return, her own testimony demonstrates that she authorized the
filing of the joint return. Petitioner admitted that when she
called the accountant in Baltimore to give the information on
what she owed, he specifically told her that she and Mr.
Merendino were going to file a joint return, and petitioner did
not object. Therefore, petitioner’s contention that the return
was filed without her permission is also contradicted by her own
testimony.
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Last modified: May 25, 2011