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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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