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collection.” And, in section 6651(g)(1), a return prepared by
the Commissioner shall be disregarded for purposes of section
6651(a)(1), which imposes an addition to tax for failure to file
any “return”.
Petitioner argues, on the basis of the aforementioned Code
sections, that “Where I.R.C. � 6020(b) returns are not to be
‘good and sufficient for all legal purposes,’ Congress has either
specifically stated the legal purpose for which they will not be
good and sufficient (as in I.R.C. � 6501(b)(3))”. However, we do
not find that the language of section 6020(b)(2) is limited only
where Congress does so expressly. Our decisions in Millsap v.
Commissioner, supra, and Healer v. Commissioner, supra, dealt
with situations where Congress did not impose any specific
limitation on section 6020(b)(2) with respect to the Code
sections involved, and we are not prepared to say that those
cases were incorrectly decided.
Further, we might add that Congress impliedly recognized
that section 6020(b)(2) has limited application when it enacted
section 6651(g)(2): Section 6651(g)(2) treats a section 6020(b)
return as a return of the taxpayer for purposes of section
6651(a)(2) and (3). Petitioner, however, argues that section
6651(a)(2) is an example of a provision that is so “narrowly
drawn” that the term “return” can only be interpreted to refer to
a return filed by the taxpayer. Despite petitioner’s
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