- 30 -
it purports to be a return, is sworn to as such * * * and evinces
an honest and genuine endeavor to satisfy the law. This is so
[even] though at the time of filing the omissions or inaccuracies
are such as to make amendment necessary." Zellerbach Paper Co.
v. Helvering, 293 U.S. 172, 180 (1934).
In 1985, petitioner filed appropriate extensions and
eventually filed what he labeled a "tentative return" on a Form
1040. The document did not include any information on income,
deductions, credits or exclusions, although it did list $20,329
in line 56 as the "total tax". It also displayed the legend:
"Ongoing Grand Jury Investigation May Materially Affect Tax
Liability". Even with an "estimated tax" listed in the "total
tax" line, the form still lacked the minimum information
prescribed by the regulations.18 It did not evince an honest and
genuine endeavor to satisfy the law. Id.; see also, e.g., Porth
v. United States 426 F.2d 519, 522-523 (10th Cir. 1970) (name and
address on a form is insufficient to be a valid return because it
fails to "contain any information relating to the taxpayer's
income from which the tax can be computed * * * within the
meaning of the Internal Revenue Code or the regulations adopted
by the Commissioner"); United States v. Jordan, 508 F.2d 750, 752
(7th Cir. 1975) (same); Ross v. Commissioner, T.C. Memo. 1984-27
18"Each taxpayer should carefully prepare his return and set
forth fully and clearly the information required to be included
therein. Returns which have not been so prepared will not be
accepted as meeting the requirements of the Code." Sec. 1.6011-
1(b), Income Tax Regs.
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