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determined does not transform his files into a section 6020(b)
return. See Cabirac v. Commissioner, 120 T.C. ___ (2003).
The documents attached to respondent’s response to
petitioner’s motion for partial summary judgment for 1996 and
1997 consist of: (1) Half-page printouts of numerous codes and
information which the Court is unable to translate; (2) portions
of pages 1 of Forms 1040, each of which contains petitioner’s
name, address, Social Security number, and filing status; (3)
computer-generated Forms 5344(CG), Examination Closing Record,
each of which contains numerous codes and listings including
petitioner’s tax liability, penalty, and interest adjustments,
credit and tax computation adjustments; (4) manually completed
Forms 5344 signed by a tax examiner containing codes and
information which the Court is also unable to translate; (5) a
Form 4549-CG, Income Tax Examination Changes; and (6) a Letter
915(DO)(CG) (the “30-day letter”)19 for petitioner’s 1995, 1996,
and 1997 tax years. Only the Form 5344 document and the 30-day
letter were signed.20
The dates which appear on the numerous documents that
respondent alleged to be section 6020(b) returns do not match;
19Letter 915(DO)(CG) provides notice to the taxpayer of
proposed adjustments to his or her tax liability. The letter is
commonly referred to as a “30-day letter”, because the taxpayer
has 30 days to agree or disagree with the proposed adjustments.
20Respondent’s revenue agent, Chris English, signed the 30-
day letter.
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