- 16 - specified by section 6091 and the regulations promulgated thereunder, or whether it contains the taxpayer's original signature. Petitioner contends that respondent used the photocopies of petitioner's 1989 and 1990 returns in formulating the audit of petitioner's returns and, thus, treated the returns "as filed". It has long been held that in order for the period of limitations on assessment and collection prescribed by section 6501 and its predecessors to run against the United States, a taxpayer must meticulously comply with all conditions for application of the statute. See Lucas v. Pilliod Lumber Co., 281 U.S. 245, 249 (1930); Florsheim Bros. Drygoods Co. v. United States, 280 U.S. 453 (1930); Bachner v. Commissioner, 81 F.3d 1274, 1280 (3d Cir. 1996). As mentioned above, section 6501(a) prescribes that the tax "shall be assessed within 3 years after the return is filed". As the Supreme Court has noted, "The word 'return' is not a technical word of art." Florsheim Bros. Drygoods Co. v. United States, supra at 462. There are four elements in determining whether a document is sufficient for statute of limitations purposes: First, the document must contain sufficient data to calculate the taxpayer's tax liability; second, it must purport to be a return; third, there must be an honest and reasonablePage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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