Cite as: 506 U. S. 523 (1993)
Opinion of the Court
to S corporations. Section 6012(a)(2) requires both Sub-chapter C and Subchapter S corporations to file income tax returns.8 Section 6037(a) specifies the information that each S corporation's return must provide (including "each shareholder's pro rata share of each item of the corporation") and further states that "[a]ny return filed pursuant to this section shall, for purposes of [26 U. S. C. §§ 6501-6531], be treated as a return filed by the corporation under section 6012."
We do not see that these provisions aid petitioner's cause. Read together, §§ 6012(a)(2), 6037(a), and 6501(a) establish only that each S corporation must file a tax return containing certain information and that a Commissioner desiring to make an assessment must act within three years of filing. Nothing on the face of these provisions demonstrates that an individual's income tax return is brought within the compass of § 6037(a)'s reference to "any return" simply because a portion of that return reports income and losses that have passed through from the return of an S corporation. If anything, the phrase "[a]ny return filed pursuant to this section," coupled with the fact that § 6037(a) is concerned with describing the contents of the corporation's return, indicates that the provision is not meant to determine when the assessment period for a shareholder's individual tax return begins.
Petitioner argues that this reading of the relevant provisions runs afoul of the fact that, prior to 1966, S corporations were not subject to taxation. According to petitioner, no purpose would have been served by establishing an assessment period that applied to returns reporting corporate income on which no taxes could be assessed but not to the
8 Section 6012(a)(2) reads: "§ 6012. Persons required to make returns of income "(a) General rule
"Returns with respect to income taxes under subtitle A shall be made by the following: . . .
"(2) Every corporation subject to taxation under subtitle A . . . ."
529
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