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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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