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(1986). In Phillips v. Commissioner, supra at 437-438, 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.18 In Millsap v. Commissioner, supra,
the Commissioner prepared a Form 1040 and attached a revenue
agent’s report which contained sufficient information from which
to compute the taxpayer’s tax liability. The attached report was
subscribed, and we held that the Form 1040 together with the
attached revenue agent’s report containing information from which
the tax could be computed met the requirements for a section
6020(b) return. The same elements we found necessary to
constitute a section 6020(b) return in Millsap v. Commissioner,
supra, and Phillips v. Commissioner, supra, are generally
required for purposes of a section 6020(b) return in the context
of section 6651(a)(2) and (g)(2). Namely, the return must be
subscribed, it must contain sufficient information from which to
compute the taxpayer’s tax liability, and the return form and any
attachments must purport to be a “return”. The mere fact that
respondent’s files contain information upon which a tax might be
18A “dummy return” is “generated to open up an account for
the taxpayer on the master file, and normally consists of a first
page of a Form 1040 which contains a taxpayer’s name, address and
social security number.” Internal Revenue Manual, Chief Counsel
Directives Manual-Tax Litigation, sec. 35.4.27.2 (Nov. 16, 1999).
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