Frederic S. Clayton and Marlene B. Clayton - Page 14

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            Sec. 6211(a)(1)(A) and (B).  It is apparent from the language of                             
            section 6211(a)(1)(A) that at a minimum the taxpayer must file a                             
            return for the amount of tax reflected therein to reduce the                                 
            taxpayer's deficiency.                                                                       
                  Every document a taxpayer files containing computations, and                           
            tax information is not a return.  Friedman v. Commissioner, 97                               
            T.C. 606, 610 (1991); Thompson v. Commissioner, 78 T.C. 558, 562                             
            (1982); Reiff v. Commissioner, 77 T.C. 1169 (1981).  For example,                            
            to qualify as a return, the Form 1040 must state specifically the                            
            amounts of gross income and the deductions and credits claimed.                              
            Thompson v. Commissioner, supra.  The same rationale regarding                               
            Form 1040 is equally applicable to an amended tax return.                                    
                  After the due date of the original return, an amended return                           
            constitutes a supplement or amendment to the original Form 1040.                             
            See Zellerbach Paper Co. v. Helvering, 293 U.S. 172 (1934).                                  
            Accordingly, to qualify as an amended return, the document must                              
            supply sufficient data from which the Commissioner can compute                               
            and assess the taxpayers' new tax liability.  At a minimum, such                             
            data should include the nature and amount of the change.  In our                             
            self-reporting tax system, the Commissioner should not be forced                             
            to accept as a return a document which plainly is not intended to                            
            give the required information.  United States v. Moore, 627 F.2d                             
            830, 835 (7th Cir. 1980); McCaskill v. Commissioner, 77 T.C. 689,                            
            698-699 (1981).  Neither the cover letter filed by petitioners                               
            nor the conversations between petitioners' accountant and                                    




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