Stephen P. and Sharon L. Sherwood - Page 7

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          respondent's determinations that petitioners failed to file                 
          sufficient tax returns are presumed to be correct and petitioners           
          bear the burden of proving her determinations erroneous.  Rule              
          142(a); Cluck v. Commissioner, supra at 339.                                
               Section 6011(a) requires all taxpayers to make a return or             
          statement according to the forms and regulations prescribed by              
          the Secretary.  A document constitutes a valid return if it                 
          contains sufficient data from which respondent can compute and              
          assess a tax liability.  McCaskill v. Commissioner, 77 T.C. 689,            
          696-697 (1981).                                                             
               Respondent's position is that petitioners' submitted Forms             
          1040-NR for 1992 and 1993 do not constitute valid income tax                
          returns.  We agree with respondent.  Petitioners have not proven            
          that the Forms 1040-NR sufficiently listed items of gross income,           
          deductions, or calculations of taxes by which their proper tax              
          liability could be ascertained.  The attachment of Forms W-2 does           
          not substitute for information required to be shown on the                  
          returns.  See Beard v. Commissioner, 82 T.C. 766, 779 (1984).               
               As was the case with their failure to file a timely return             
          for 1991, petitioners have not shown that such failure was due to           
          reasonable cause.  Therefore, respondent's determinations that              
          petitioners are liable for the section 6651(a)(1) addition to tax           
          for 1992 and 1993 are sustained.                                            
               The fifth issue for decision is whether petitioners are                
          liable for the section 6663(a) fraud penalty for 1991.  In her              




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