- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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