- 29 - 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, "ifPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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