Jack J. Kramer - Page 29

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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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