Michael A.Cabirac - Page 14

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          438 (1986), affd. in part and revd. in part on another issue 851            
          F.2d 1492 (D.C. Cir. 1988), we held that a “dummy return”, i.e.,            
          page 1 of a Form 1040 showing only the taxpayer’s name, address,            
          and Social Security number, was not a section 6020(b) return.  In           
          Millsap v. Commissioner, 91 T.C. 926 (1988), respondent prepared            
          Forms 1040 containing the taxpayer’s name, address, Social                  
          Security number, and filing status.  The Forms 1040 contained no            
          information regarding income or tax and were not subscribed.                
          However, attached to the Forms 1040 was a previously prepared               
          revenue agent’s report which contained sufficient information               
          from which to compute the taxpayer’s tax liability and was                  
          subscribed.  We held that the Form 1040 together with the                   
          attached revenue agent’s report met the requirements for a                  
          section 6020(b) return.                                                     
               The SFRs that the parties stipulated were not subscribed as            
          required by section 6020(b)(2) and show zeros on the relevant               
          lines for computing a tax liability, and do not show any tax due.           
          Indeed, the SFRs contain essentially the same information and               
          entries as the forms petitioner submitted as returns for 1997 and           
          1998, and we have already held that the forms submitted by                  
          petitioner were not valid returns.  Moreover, although each of              
          the SFRs contains pages 1 and 2 of a Form 1040, those documents             
          are essentially the same as the “dummy returns” which we held did           
          not constitute section 6020(b) returns in Phillips v.                       






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