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taxable years 1987 through 1991, his Federal income tax returns
were due on June 15 of the year following the close of the
taxable year. Sec. 6072(c). As of November 13, 1992, petitioner
had not filed any Federal income tax returns for the years in
issue. On that date, respondent mailed a letter to petitioner
asking him if he had filed returns and, if he had not,
instructing him to file returns or otherwise respond. That
letter also stated that, if petitioner did not respond by
December 1, 1992, respondent would file substitute returns for
him. Petitioner did not respond, and on January 12, 1993,
respondent again wrote petitioner with the same request, adding
that, if there was no response within 20 days, "your tax
liability [will be determined] based on the information we have."
Again petitioner did not respond. On February 3, 1993,
respondent notified petitioner that respondent had filed
substitute returns for the taxable years 1987 through 1991. On
March 23, 1993, respondent informed petitioner that the
substituted returns were computed without the benefit of any
deductions.
On October 7, 1993, petitioner submitted Federal income tax
returns for all the years in issue. The returns reflected the
net losses from the rental properties described above. Each
return contained an election pursuant to section 871(d), to treat
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