Gary Friedmann - Page 17




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             attempt to satisfy the requirements of the tax law; and                  
             fourth, the taxpayer must execute the document under                     
             penalties of perjury.  Beard v. Commissioner, 82 T.C. 766,               
             777 (1984), affd. 793 F.2d 139 (6th Cir. 1986).  In order                
             to have the effect of a return for statute of limitations                
             purposes, a key element is that the document "must honestly              
             and reasonably be intended as such" by the taxpayer.                     
             Florsheim Bros. Drygoods Co. v. United States, supra at                  
             462.                                                                     
                  Among other filing requirements, the Internal Revenue               
             Code specifies that a return "shall be signed in accordance              
             with forms or regulations prescribed by the Secretary",                  
             sec. 6061(a), it "shall contain or be verified by a written              
             declaration that it is made under the penalties of                       
             perjury", sec. 6065, and it shall be filed at the place                  
             specified by the Internal Revenue Code and the regulations               
             promulgated thereunder, sec. 6091.  In the case of the                   
             return of an individual, the general rule is that the                    
             return shall be made to the Secretary in the internal                    
             revenue district in which is located the taxpayer's legal                
             residence or principal place of business, or it shall be                 
             made at the service center serving one of those districts.               
             Sec. 6091(b)(1).                                                         








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