Phyllis J. Merendino - Page 9

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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            
               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            

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