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Held: The wages, interest, and distributions that
P received represent taxable income in the amounts
determined by R.
Held, further, that P is liable for a 10-percent
additional tax on the taxable amounts of his pension
and IRA distributions. Sec. 72(t)(1), I.R.C.
Held, further, that P is liable for sec.
6651(a)(1), I.R.C., additions to tax for failure to
file a return on or before the specified filing date.
The Forms 1040 and 1040A that P filed showing zeros are
not “returns” for Federal income tax purposes. P is
also liable for sec. 6654, I.R.C., additions to tax for
a failure to pay estimated taxes.
Held, further, that the sec. 6651(a)(2), I.R.C.,
additions to tax for failure to pay amounts of tax
shown on returns do not apply because there was no tax
shown on any returns attributable to P, and the
unsubscribed substitutes for return showing zero taxes
do not meet the requirements for a sec. 6020(b),
I.R.C., return. The subsequently prepared notice of
proposed adjustments and the revenue agent’s report,
which were not attached to the unsubscribed substitutes
for return, whether viewed separately or in conjunction
with the substitutes for return, do not constitute
returns for purposes of sec. 6020(b), I.R.C.
Held, further, that a penalty of $2,000 is imposed
under sec. 6673(a)(1), I.R.C.
Michael A. Cabirac, pro se.
James N. Beyer, for respondent.
RUWE, Judge: Respondent determined the following
deficiencies in petitioner’s Federal income taxes and additions
to tax as follows:
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