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petitioner is precluded from arguing that his unpaid liabilities
were discharged in bankruptcy.
Background
The parties submitted this case fully stipulated. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference. Petitioner resided in Lake Dallas,
Texas, at the time his petition was filed.
Petitioner did not file Forms 1040, U.S. Individual Income
Tax Return, for the taxable years 1993, 1994, and 1995. Copies
of MFTRA-X transcripts of petitioner’s accounts for the tax years
at issue reflect that respondent filed “substitutes for return”1
(SFRs) for these years on February 24, 1997. On May 28, 1997,
respondent issued a notice of deficiency to petitioner
determining deficiencies in and additions to his Federal income
taxes for 1993, 1994, and 1995. Petitioner filed a petition and
an amended petition with this Court seeking a redetermination.
On February 3, 1998, the Court dismissed the case for failure to
state a claim upon which relief could be granted and decided that
1The Commissioner has previously represented to this Court
that the term “substitute for return” (SFR) is a term used by the
Commissioner for returns or partial returns prepared by the
Commissioner where the taxpayer did not file a return. Spurlock
v. Commissioner, 118 T.C. 155, 156 n.2 (2002). The term SFR has
also been used to describe a return prepared by the Commissioner
under sec. 6020(b). We note that respondent does not allege and
the evidence in the record does not indicate whether the returns
prepared by respondent in this case meet the requirements of sec.
6020(b). For convenience, we refer to the returns prepared by
respondent as SFRs.
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