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Petitioner advances an alternative argument as to why the 3-
year look-back period in section 6511(b)(2)(A) applies in the
instant case. Petitioner argues that, for purposes of section
6511(a), respondent’s substitute for return for petitioner’s tax
year 1996 constitutes a return filed by the taxpayer, here
petitioner, on or before April 28, 1999, the date on which
respondent issued the notice to her. Consequently, according to
petitioner, the 3-year look-back period in section 6511(b)(2)(A)
applies in the instant case. Respondent counters that a substi-
tute for return prepared by respondent pursuant to section
6020(b)(1) does not constitute a return filed by the taxpayer for
purposes of section 6511(a) and that therefore petitioner’s
alternative argument should be rejected. We agree with respon-
dent.
In support of her position that respondent’s substitute for
return for petitioner’s tax year 1996 constitutes a return filed
by the taxpayer for purposes of section 6511(a), petitioner
relies on section 6020(b)(2). Section 6020(b) provides in
pertinent part:
SEC. 6020. RETURNS PREPARED FOR OR EXECUTED BY
SECRETARY.
(b) Execution of Return by Secretary.--
(1) Authority of secretary to execute
return.–-If any person fails to make any return
required by any internal revenue law or regulation
made thereunder at the time prescribed therefor
* * *, the Secretary shall make such return from
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