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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 reasonable
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