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Petitioner nevertheless contends that section
6012(a)(1)(A)(i) and the instructions for Form 1040 insulate him
from having to file a tax return for 1997.4 Even if true,
petitioner’s contention does not account for section 6001, which
provides in part:
Whenever in the judgment of the Secretary it is
necessary, he may require any person, by notice served
upon such person or by regulations, to make such
returns, render such statements, or keep such records,
as the Secretary deems sufficient to show whether or
not such person is liable for tax under this title.
The term “make” as used in section 6001 encompasses the entire
process of completing and filing the required return. Aldrich v.
Commissioner, T.C. Memo. 1993-290. Respondent notified
petitioner of section 6001 on numerous occasions, including but
not limited to the letter dated November 5, 2002, from
4 Sec. 6012(a)(1)(A)(i) provides:
SEC. 6012(a). General Rule.--Returns with respect to
income taxes * * * shall be made by * * *
(1)(A)Every individual having for the taxable year
gross income which equals or exceeds the exemption
amount, except that a return shall not be required of
an individual--
(i)who is not married (determined by
applying section 7703), is not a surviving
spouse (as defined in section 2(a)), is not a
head of household (as defined in section
2(b)), and for the taxable year has gross
income of less than the sum of the exemption
amount plus the basic standard deduction
applicable to such an individual.
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