Sandra L. Andary-Stern - Page 10




                                       - 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 from           








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