- 17 - attempt to satisfy the requirements of the tax law; and fourth, the taxpayer must execute the document under penalties of perjury. Beard v. Commissioner, 82 T.C. 766, 777 (1984), affd. 793 F.2d 139 (6th Cir. 1986). In order to have the effect of a return for statute of limitations purposes, a key element is that the document "must honestly and reasonably be intended as such" by the taxpayer. Florsheim Bros. Drygoods Co. v. United States, supra at 462. Among other filing requirements, the Internal Revenue Code specifies that a return "shall be signed in accordance with forms or regulations prescribed by the Secretary", sec. 6061(a), it "shall contain or be verified by a written declaration that it is made under the penalties of perjury", sec. 6065, and it shall be filed at the place specified by the Internal Revenue Code and the regulations promulgated thereunder, sec. 6091. In the case of the return of an individual, the general rule is that the return shall be made to the Secretary in the internal revenue district in which is located the taxpayer's legal residence or principal place of business, or it shall be made at the service center serving one of those districts. Sec. 6091(b)(1).Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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