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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 from
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