Frederic S. Clayton and Marlene B. Clayton - Page 15

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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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