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respondent's employees explained what item petitioners were
changing or the reason for the change. We find that neither
constituted an amended return.
To support their argument, petitioners rely upon section
6103(b) and section 9781.348.2 of 6 Administration, Internal
Revenue Manual (CCH), 28,689-5 through 28,690 (I.R.M. or manual).
Section 6103(b) provides in pertinent part:
Definitions.--For purposes of this section--
(1) Return.--The term “return” means any tax or
information return, declaration of estimated tax, or
claim for refund required by, or provided for or
permitted under, the provisions of this title which is
filed with the Secretary by, on behalf of, or with
respect to any person, and any amendment or supplement
thereto, including supporting schedules, attachments,
or lists which are supplemental to, or part of, the
return so filed.
* * * * * * *
(2) Return Information.-- The term "return
information" means
(A) a taxpayer's identity, the nature,
source, or amount of his income, payments,
receipts, deductions, exemptions, credits, assets,
liabilities, net worth, tax liability, tax
withheld, deficiencies, overassessments, or tax
payments, whether the taxpayer's return was, is
being, or will be examined or subject to other
investigation or processing, or any other data,
received by, recorded by, prepared by, furnished
to, or collected by the Secretary with respect to
a return or with respect to the determination of
the existence, or possible existence, of liability
(or the amount thereof) of any person under this
title for any tax, penalty, interest, fine,
forfeiture, or other imposition or offense, and *
* * be associated with or otherwise identify,
directly or indirectly, a particular taxpayer.
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