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Accordingly, we find that petitioner has unexplained bank
deposits in the amounts set forth in our concluding findings,
with resulting decreased deficiencies for 1985 and 1986. The
unexplained deposits for 1987 are as the parties have stipulated
for that year.
Issue 2. Additions to Tax for 1985
a. Failure to file a return--section 6651
Section 6011(a) requires that "any person made liable for
any tax * * * shall make a return or statement according to the
forms and regulations prescribed by the Secretary." Treasury
regulations require that returns contain "therein the information
required by the applicable regulations or forms." Sec. 1.6011-
1(a), Income Tax Regs. Failure to file a return subjects a
taxpayer to additions to tax under section 6651(a)(1) of "5
percent for each additional month * * * not exceeding 25
percent".
To be a return that starts the period of limitations, a
document must "purport to be a specific statement of the items of
income, deductions, and credits in compliance with the statutory
duty to report information and `to have that effect it must
honestly and reasonably be intended as such'". Beard v.
Commissioner, 82 T.C. 766, 778 (1984), affd. 793 F.2d 139 (6th
Cir 1986) (quoting Florsheim Bros. Drygoods Co. v. United States,
280 U.S. 453, 462 (1930)). However, a document may be sufficient
to be a return, even if not perfectly accurate or complete, "if
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