- 10 - I. “The greatness of our nation is in no small part due to the willingness of our citizens to honestly and fairly participate in our tax collection system”. Hatfield v. Commissioner, 68 T.C. 895, 899 (1977). The method by which citizens complete the initial step of their annual participation in our tax collection system is, of course, to self-assess their income tax liabilities by filing income tax returns, and by paying the liabilities shown thereon. See Reif v. Commissioner, 77 T.C. 1169, 1179 (1981). In the case at hand, the originating cause of petitioner’s problems is her failure to file timely Federal income tax returns for the years 1987, 1988, 1991, 1992, 1993, and 1994. Even though petitioner was delinquent in not filing returns and paying her tax liabilities, her employers and other third parties filed information returns indicating she had earned wages and received unemployment compensation and gambling winnings. From the information returns, respondent concluded that petitioner was required to file returns for the years at issue and undertook to prepare substitute returns on her behalf. The Commissioner’s authority to prepare substitute returns derives from section 6020(b)(1), which provides that if “any person fails to make any return required by any internal revenue law or regulation * * * the Secretary shall make such return fromPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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