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purposes: (1) There must be sufficient data to calculate the tax
liability, (2) the document must purport to be a return, (3)
there must be an honest and reasonable attempt to satisfy the
requirements of the tax law, and (4) the taxpayer must execute
the return under penalty of perjury. Badaracco v. Commissioner,
464 U.S. 386 (1984); Beard v. Commissioner, supra at 777-778;
see also Zellerbach Paper Co. v. Helvering, 293 U.S. 172 (1934);
Florsheim Bros. Drygoods Co. v. United States, 280 U.S. 453
(1930); National Contracting Co. v. Commissioner, 105 F.2d 488
(8th Cir. 1939), affg. 37 B.T.A. 689 (1938). On their bogus form
petitioners created false "adjustments to income", subtracting
each item of "gross receipts" they had listed, to arrive at a net
income of zero. Moreover, petitioners altered the jurat
significantly. A jurat is required to be made according to the
forms prescribed by the Secretary. Sloan v. Commissioner, 102
T.C. 137, 146-147 (1994), affd. 53 F.3d 799 (7th Cir. 1995).
In light of the above, we conclude that none of the
documents filed by petitioners for the years in issue demonstrate
an honest endeavor to satisfy the law. We hold that petitioners
did not file Federal income tax returns for the years in issue.
Petitioners' arguments concerning the conflict between
section 61(a) and the 16th Amendment are not well taken. The
Supreme Court has defined "income" as "undeniable accessions to
wealth, clearly realized, and over which the taxpayers have
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