528
Opinion of the Court
By contrast, the S corporation's return, which petitioner asserts triggers the beginning of the limitations period, is deficient precisely because it does not contain all of the information necessary to compute a shareholder's taxes. If the Internal Revenue Service were required to rely on that return, it would be forced to conduct its assessment on the basis of incomplete information:
"While [the corporate return] may show petitioner's distributive share of losses, it does not indicate his adjusted basis in his corporate stock, which is information necessary to determine if the loss is deductible. Nor does it show petitioner's income, losses, deductions, and credits from other sources. Moreover, the information return of the S corporation does not relate to the same taxable period as petitioner's return . . . ." Fehlhaber, supra, at 869 (citation omitted).
As noted in analogous cases, tax returns that "lack the data necessary for the computation and assessment of deficiencies" generally should not be regarded as triggering the period of assessment. Automobile Club of Mich. v. Commissioner, 353 U. S. 180, 188 (1957) (citing Commissioner v. Lane-Wells Co., 321 U. S. 219 (1944)).7
Petitioner asserts that § 6501(a) supports a contrary view when read in light of two related Code provisions pertaining
a reasonable one to say the least, and we should accept it absent convincing grounds for rejecting it. As noted in Badaracco v. Commissioner, 464 U. S. 386 (1984), " 'limitations statutes barring the collection of taxes otherwise due and unpaid are strictly construed in favor of the Government.' " Id., at 392 (quoting Lucia v. United States, 474 F. 2d 565, 570 (CA5 1973)).
7 In these circumstances, the incompleteness of the corporate return provides a reason for doubting petitioner's understanding of the Code. We do not thereby suggest that, for cases in which a corporate return does supply all of the information necessary to process a shareholder's return, the mere fact of completeness is sufficient to establish the corporate return as "the" return of § 6501(a).
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