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Internal Revenue Code]." (Emphasis added.) In this case,
petitioners, by reason of the disclaimer, have not self-assessed
any tax on the basis of the Document, which cannot therefore
qualify as a return. See Sloan v. Commissioner, supra.
Since petitioners did not file a return for their 1995
taxable year, section 6664(b) prevents imposition of the
accuracy-related penalty under section 6662(a).
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011