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preparer, petitioner does not contend, and the evidence does not
show, that the preparer’s signature qualifies as the signature of
a duly authorized agent for Astrid Downing pursuant to the
regulations.
Petitioner’s testimony regarding the circumstances of his
purported filing of his 1995 income tax return was vague and
inconsistent; conspicuously absent from his testimony was any
convincing explanation of how or when Astrid Downing allegedly
signed a joint return. Petitioner did not call Astrid Downing as
a witness and has otherwise offered no credible evidence to
establish that Astrid Downing ever intended to file a 1995 joint
return with him or that she even tacitly consented to the filing
of a joint return for 1995. Astrid Downing’s intent in this
regard is made more problematic by the undisputed fact that
before the amended 1995 joint return was purportedly filed, she
had filed a “Single” return for 1995 under a name other than her
married name and listed an address other than petitioner’s
Singapore address. Petitioner has failed to persuade us that
Astrid Downing ever intended to file a 1995 joint return with
him.
10(...continued)
additional forms and schedules. Petitioner has not adequately
explained how these two versions came about or why he included
the Oct. 15, 1996, version in his Apr. 11, 2001, correspondence
with the IRS but now appears to claim the Oct. 25, 2001, version
as the relevant one.
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